Transfer Tragedy: A Timeworn PBM Target

It’s a tale almost as old as time – a patient’s medication is sent to one pharmacy only to have the patient decide they want it filled by your pharmacy instead. You contact the other pharmacy for a transfer, fill the medication and the patient is on their way. All is well until you receive a PBM audit. Suddenly, that transferred prescription is under scrutiny, and you are wondering what the problem could possibly be.

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Transferred prescriptions have become an easy target for PBMs due to their additional documentation each state requires, which can be easily forgotten in the rush to take down all the information. PBMs identify transferred prescriptions through the origin code billed and will look for any technicality to recoup (e.g., missing the word “transfer” on the prescription). Check your state’s transfer requirements to ensure all elements are present on your transferred prescriptions, regardless of how the transfer is received (e.g., via fax or verbally). The receiving pharmacy is responsible for ensuring all transfer requirements are present, so if any elements are missing, verify them and make note of the missing information on the prescription.

PBMs also look for other missing or inaccurate information. Some PBMs, like Humana, will interpret state laws referencing a transferred prescription be “reduced to writing” as needing to be hand-written by the receiving pharmacy. Additionally, if the original written date of the prescription is missing or entered incorrectly, the claim could be flagged for “wrong hard copy,” and risks being refilled after expiration. Finally, the quantity on a transfer needs to be specific and contain a unit of measure. For example: insulin pens written with a quantity of 15 without a unit of measure, should be clarified with the transferring pharmacy as 15 mL, 15 pens, or 15 boxes.

PAAS Tips:

  • Check with PAAS (or your Board of Pharmacy regulations) for your state’s transfer requirements
    • Have pre-printed transfer prescription pads available with blanks for all required information
    • Make sure pharmacy staff are aware of the importance of filling out the transfers completely
  • Print any internal transfer screens used to satisfy state requirements and send along with your prescription for audit
  • Never dispense more than the quantity remaining on the prescription
  • Enter the correct written date to avoid filling after expiration
  • Enter Origin Code 5 (sometimes listed as “Transfer” or “Pharmacy” in your software) no matter how you receive the transfer from the other pharmacy
  • Ensure the unit of measure is present on quantities that may have multiple interpretations
  • If the prescription was on hold at the transferring pharmacy, make note of it on the transfer

Jenevra Azzopardi, CPhT