UPDATE: Many PBMs Have Continued to Add or Extend Relaxations During COVID-19

In an effort made in response to the COVID-19 emergency thus far, as previously discussed in our posts, “What Are the PBMs Doing Amid COVID-19 Crisis: Waivers from Strict Requirements May Exist for Independent Pharmacies,” and “UPDATE: Humana and Prime Therapeutics’ Response to Waivers from Strict Requirements for Independent Pharmacies Amid COVID-19 Crisis,” many Pharmacy Benefit Managers (“PBMs”) have taken further steps to extend their relaxed requirements or provide additional flexibilities as COVID-19 continues to impact access to patient care across the country.

Certain PBMs have announced new formal policies aimed at easing the impact of COVID-19 on network providers.  For example, MedImpact has removed the requirement for documenting the full name and relationship of the person picking up the prescription. EnvisionRx has recently announced that it has canceled or postponed pharmacy audits as of March 16, 2020. MeridianRx has declared that they will not send notices of audit requests for dates of services beginning March 15, 2020 through the end of May. Due to no-contact delivery methods, MeridianRx has also waived the patient signature requirements for claims with dates of services of March 15, 2020 or after, until the waiver is lifted.

Other PBMs have indicated that they will be continuing or extending previously-issued guidance.  For example, Navitus has stated that they are extending their waivers through the end of May and that pandemic situation is currently being evaluated on a monthly basis. Express Scripts, Inc. has announced their temporary policy with respect to obtaining patient signatures has been extended until further notice. Lastly, Humana has also stated that their waivers for signature log and mailing requirements has been extended through May 2020. In the same vein, Humana’s non-FWA audits will continue to remain on hold and Humana will release further communications by May 31, 2020.

How Frier Levitt Can Help

Frier Levitt is actively assisting pharmacies seeking waivers from State Boards of Pharmacy, PBMs and CMS during these challenging times and is monitoring these changes so that we can continue to provide you with timely updates as circumstances change. For more information on how to address these PBM practices, contact Frier Levitt to speak with an attorney.

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