Pharmacy ALERT: CVS Caremark Nearly Doubles Drugs on “Aberrant Quantities” Product List Effective January 2021

In 2019, Frier Levitt reported a new dispensing limitation CVS Caremark (“Caremark”) introduced in its retail networks that took effect on January 1, 2020. Specifically, Caremark issued an “Aberrant Product List” that identified approximately 300 drug products that the pharmacies were required to monitor their dispensing for.  Thereafter, Caremark has been imposing penalties upon the pharmacies that dispense medications listed in the Aberrant Product List beyond 25% or more of the pharmacy’s claims or reimbursement amount.  Needless to say, such a limitation on the pharmacy’s dispensing ability placed additional burden upon the pharmacy when the pharmacy has been focusing on treating patients in the midst of the novel coronavirus pandemic.  More troubling, Caremark recently issued an updated Aberrant Product List (“Updated List”) that went into effect January 1, 2021.  
The Updated List contains nearly double the number of drugs included in the original Aberrant Product List.  The number of new drugs and the therapeutic class of the drugs added to the Update List are highly concerning.  Certainly, the Updated List will impact the pharmacy’s ability to treat patients and the day-to-day operation.  Per Caremark, a pharmacy is in breach of the Provider Manual if, in a one-month period, the pharmacy’s dispensing of drug products on the Aberrant Product List accounts for 25% or more of the pharmacy’s claims or reimbursement amount.  Should any pharmacy exceed this threshold, the pharmacy will be informed of the “breach” and required to cure the breach, and a continued failure to adhere to the threshold may result in further action, including but not limited to, chargeback of the applicable claims and even termination.
How Frier Levitt Can Help
Pharmacies who are subject to this Aberrant Product List are encouraged to review their dispensing practices and overall drug mix, but more importantly, should consult us today to understand the implications and potential consequences of the Updated Aberrant Product List.
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