PAAS National® recommends attention to detail when it comes to typing directions for patient labels. Many PBMs require the patient label directions match the prescription directions exactly, or a pharmacy may face recoupment for a “misfilled” prescription.
Errors on the patient label can range from simple typos to dosing errors. Even seemingly innocuous additions to the patient label (e.g., a diagnosis code or time of administration) can lead to potential audit discrepancies when added without prescriber approval (or documentation). If the prescription directions are clarified with the prescriber’s office, make sure to add a clinical note and update the patient label. See our November 2020 article Are Your Pancreatic Enzyme Prescriptions Audit Ready? for a common issue between the prescription directions and patient label.
Another problematic patient label issue PAAS frequently sees is regarding units. Consider Victoza®, which typically has directions in mg, but has often been mistyped as mL. See our January 2021 article Victoza – One Letter Can Cost You! for more detail.
PAAS Tips:
Become an audit assistance member today to continue reading this article. As a member, you’ll have access to hundreds of articles and receive our monthly proactive newsletter!
Did you know there is much more to your audit assistance membership than just help with audits? The PAAS Member Portal contains a wealth of information and resources to assist you with audits and member service questions. Below is a list of 6 pages found on the Audit Assistance section of the PAAS Member Portal to assist you and your pharmacy staff to be proactive when it comes to audits.
- Access Services
- Audit Documentation Submission Guidance
- An online form to submit safe filling and billing questions
- Your PAAS Membership Manual
- Newsline
- Monthly newsletter articles, written by our expert PAAS analyst team, provide safe filling and billing tips and relays relevant/current PBM trends to be help prevent audits
- Search the Newsline Archive to get PAAS tips at the click of a button
- Special Edition Newslines including: Top 10 articles of the prior year, DMEPOS Article Series and a Self-Audit Article Series
- Ability to print monthly issues or individual articles
- Proactive Tips
- Audit flags – list of various claim attributes the PBMs use to select claims for audit
- Billing insulin vials – flowchart to assist whether you should bill Medicare Part B vs Part D
- DAW Codes Explained – use to understand when to effectively use DAW codes, their definitions and why claims may be flagged for audit if a DAW code is used incorrectly
- Basic DMEPOS documentation guidance
- Onsite Credentialing Checklist and expanded definitions of policies and procedures
- Proof of refill request and affirmative response form for DMEPOS items
- Steps on how to prepare for an onsite audit
- And more!
- Days’ Supply Charts
- Utilize the days’ supply charts for inhalers, insulins, nasal sprays, eye drops and topicals to aid you in calculating the correct days’ supply
- Guidance on overbilled quantities and incorrect days’ supply account for a sizable portion of audit chargebacks
- Additional miscellaneous charts, which include: Dispense in Original Container and Return to Stock
- Forms
- Signature Logbook for print
- Signature Trifold Mailer
- Fax and Email Coversheet
- Patient Attestation for over-the-counter COVID-19 test kits
- On-Demand Webinars
- Short webinars on hot topics in the PBM industry. Here are a few examples:
- USP 800 Compliance
- Cultural Competency Training
- Dispensing Prescriptions Off-Label
- Biologic Medications and Interchangeability
- Continuous Glucose Monitor Requirements for Medicare Part B
PAAS Tips:
- MORE AUDITS, MORE INSIGHT – PAAS National® is the industry-leading defender of community pharmacy dealings with Prescription Benefit Programs, including Caremark, Express Scripts, Humana, Medicaid, OptumRx, Prime Therapeutics., and more. PAAS assists on all third-party audits, including: desktop audits, onsite audits, invoice audits, OIG/Medicaid audits, Medicare B audits. The PAAS team is dedicated to helping you! We have five pharmacists and a complement of technician analysts with over 50 years of dedicated audit assistance experience. PAAS continuously updates their database with every audit received — in fact, we even keep a scorecard on individual auditors.
- Get answers to your questions on days’ supply calculations, drug substitutions, billing practices, required documentation, prior authorization requirements, record retention, and internal audit procedures – just to name a few. As a trusted partner, we will provide tailored guidance to help you proactively prevent audits. Remember, the prescription claims you submit today are the audits of the future.
- Keep your employees engaged and help lower audit risk by adding all employees to the portal and giving them permission to access these tools, resources and eNewsline. For more information review September 2019 Newsline article, What Are You Waiting For? Make Sure ALL of Your Employees are Added to the PAAS Portal!
- Contact PAAS at (608) 873-1342, if you would like a tour of your PAAS Member Portal, so you can reap all the benefits of your PAAS Audit Assistance. We appreciate you being a member.
- Label directions should be typed exactly as they appear on the prescription and mathematically calculable for days’ supply
- PBMs look to recoup on a prescription/label mismatch when it could cause a clinical error or if it appears that a clinical annotation was added after the prescription was dispensed
- Adding the route of administration is typically not an issue unless the route added is incorrect (see our September 2019 article Route of Administration is Important)
- If clarifying directions with the prescriber, the updated directions need to be included on the patient label
- Examples of instructions that should be clarified:
- Sliding Scale Insulin without a max daily dose, pancreatic enzymes taken with meals and snacks, and instructions to be taken “As Needed” should have a maximum daily dose
- “Use as Directed” – per package? Off-label? See PAAS Newsline article February 2022 Use Care with Unit of Use Packages and “Use as Directed” for more information
- Topical products should ideally contain a mathematically calculable amount to be applied per application or maximum per day. See our Topical Creams and Ointments days’ supply chart for more details
- Diagnoses should only be included if written by the prescriber
Analyst at PAAS National®
I grew up in a family of nurses and other medical professionals but was never interested in the clinic setting. I was drawn to pharmacy because I like to help people and could easily use the knowledge I grew up with to do so. It was a great fit.
I have a Bachelor of Arts in Communications from the University of Wisconsin – Madison. Prior to joining PAAS in 2017, I worked for Walgreens for 19 years.
As an Analyst at PAAS, I really enjoy being able to help independent pharmacies succeed. I have always been a fan of the underdog and am excited to be able to give you the tools you need to take on the giants of the PBM industry.
Latest posts by Jenevra Azzopardi, CPhT
(see all)
