In the course of routine PBM audits, pharmacies have always been called on to provide documentation demonstrating that prescriptions delivered by third party couriers to patients were in fact delivered. However, recent audit trends and PBM alerts indicate that there has been an increased focus on verifying proof of delivery during audits and also a shift in the type of documentation that PBMs will accept as adequate proof of delivery. Where in the past, PBMs may have accepted as sufficient a third party delivery confirmation including a patient name and address, PBMs are now seeking to recoup large amounts in the absence of more specific delivery information, such as Rx Numbers printed directly on the delivery confirmation. This shift follows other recent PBM auditing trends toward more stringent and narrow interpretations of PBM Manuals and Pharmacy Network Agreements.
PBM compliance is a moving target as changes to the Manual are not always apparent. Pharmacies are notified of policy and enforcement changes through newsletters, alerts, and updates which can be easily overlooked but are incorporated by reference into the Manual. Frier Levitt assists pharmacies with PBM audits and governmental investigations on a daily basis and is acutely aware of audit trends, investigation trends and shifts in PBM enforcement. Frier Levitt can help your pharmacy develop standard operating procedures (SOPs) for maintaining signature logs and proof of delivery which comport with state and federal requirements and also meet PBM expectations. Contact us today to speak to an attorney.
