CVS/Caremark has followed in the footsteps of other PBMs and has recently adopted new recredentialing processes for compounding pharmacies. These new recredentialing forms represent a significant change from forms that were previously used for compounding pharmacies going through recredentialing. Citing its need to comply with the Affordable Care Act and State Medicaid requirements, Caremark has tasked many of the PSAOs with ensuring these recredentialing questions are answered by compounding pharmacies.
The questionnaire asks new, specific questions of compounding pharmacies, touching on many aspects of the pharmacy’s business. Perhaps most significantly, the new recredentialing process requires the pharmacy to maintain and submit dozens of Policies and Procedures relating to various aspects of pharmacy operations and billing practices, such as USP <795> compliance, Anti-Kickback Statute compliance, and billing procedures. In addition, the recredentialing application asks pointed questions regarding the use of pharmacy marketing representatives (i.e., W-2 vs. 1099), pre-printed prescription pads, and central fill relationships.
While Caremark had been using a similar credentialing form for new compounding pharmacies for several months, Caremark is rolling this process out for all pharmacies and appears to be requiring them to complete the form by the end of December 2014.
Frier Levitt can assist pharmacies in completing this very robust application and can advise clients on compliance with the Manual as well as State and Federal laws and regulations. Frier Levitt can help your pharmacy navigate this important application process for a flat fee, affording a substantial savings off our hourly rates. If you’ve received a compounding-specific recredentialing request, contact Frier Levitt.
