Transferred prescriptions remain a common audit target, and pharmacies are facing recoupments due to missing information. Without having all required elements set in place by your state’s Board of Pharmacy, these claims are at risk of full recoupment by PBMs. Transferred prescriptions are easily identified and audited by the PBM due to the origin code.
Pharmacies receiving a faxed document from another pharmacy for a transfer must ensure all transfer requirements are included. If any requirements are missing (e.g., including the word “transfer” in some cases), the pharmacy must verify and add the information. Relying on another pharmacy to include all transfer requirements is extremely risky and could result in audit recoupments. Be aware, some states require transferred prescriptions be “reduced to writing.” PBMs like Humana have recouped claims in these states when a faxed form was used.
When PBMs like Humana, OptumRx, and Elixir flag a transferred prescription discrepant, they not only go after that claim, but all the refills under that prescription as well. Very quickly a small error can result in thousands of dollars facing recoupment.
Another way transferred prescriptions present audit risk is the invalid entry of the written date. If the receiving pharmacy fails to enter the actual written date of the prescription, the pharmacy could potentially refill past expiration. Make sure your staff is aware of the importance of entering accurate dates. PBMs are also flagging transferred insulin prescriptions if the quantity does not indicate a unit of measure (i.e., mL, pens, boxes or units).
- Check your state’s Board of Pharmacy transfer requirements and have printed for reference
- Educate all staff on your state’s prescription transfer requirements
- Pre-printed prescription pads with all your state’s transfer requirements can be very beneficial
- Pharmacies using an internal transfer screen to capture the requirements must include this during an audit
- See the Newsline’s Self-Audit Series #6 for monitoring your transfers internally