Updated Dispense in Original Container Chart

Medications that are required to be dispensed in their original container continue to appear in audits. Billing for a quantity that is not divisible by the full bottle size is a red flag to the PBM and, unfortunately, easily recoupable. Many of these products are sensitive to light/moisture or have only been studied under storage in their original container; thus, removing them from the original package may cause stability and potency issues. Product labeling can be obtained from the FDA’s DailyMed website, which was referenced by PAAS National^® to update the Dispense in Original Container chart under the Tools & Aids section of the PAAS member portal.

For example, PAAS analysts have seen an increase in

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!

Join today!

questions regarding Truvada^® for HIV post-exposure prophylaxis (PEP). Prescribers are issuing scripts for 28 days to follow the PEP treatment guidelines by the CDC, but one of the drugs included in the CDC 28-day PEP treatment regimen is Truvada^®, which comes in 30-count bottles with labeling to “dispense only in original container.” PAAS cannot recommend dispensing outside of FDA guidelines and advises the pharmacy to obtain authorization from the prescriber to dispense the full bottle.

Additionally, pharmacies dispensing to nursing homes or providing medication packaging to patients in the retail pharmacy setting must also follow the FDA guidelines to dispense in the original container.

PAAS Tips:

Print and display a copy of the PAAS National^® Dispense in Original Container chart near the billing station
Place labels on the shelf by products required to be dispensed in their original container
Only bill these products for quantities divisible by the full bottle size to decrease audit risk
If necessary, contact the prescriber for authorization to change the prescribed quantity to facilitate dispensing in the original container and document the change with a clinical note
Contact PAAS with concerns or for further clarifications

Author
Recent Posts

Sara Hathaway, PharmD

Analyst at PAAS National^®

After graduating from UW-Madison's School of Pharmacy with my PharmD, I spent my first eight years at an independent pharmacy dividing my time between both retail and long-term care. I fell in love with the independent pharmacy world and joined the PAAS team to help independents not only survive, but thrive.

I enjoy assisting pharmacy staff both pre- and post-audit and enjoy providing them with knowledge and tools to decrease audit risk going forward. I write articles for Third-Party Newsline each month and answer member questions daily. I look forward to building professional relationships with each of our members and assisting you with your next audit.

Latest posts by Sara Hathaway, PharmD (see all)

The Double Threat: Ransomware Attack Followed by HIPAA Non-Compliance Settlement - August 30, 2024
Do The Math and Avoid the Recoupment - August 8, 2024
NEW Dispense as Written (DAW) Code Revealed - July 31, 2024