Worry-Free Medicare Audits
Increased Medicare audits are raising the stakes for compliance in today’s pharmacies, with stricter enforcement than ever before. In fact, the likelihood of receiving a Part B audit request continues to climb amid national efforts to control fraud, waste and abuse.
In our first discussion of Medicare audits, we addressed three ways to improve your pharmacy’s outlook, and forward-thinking pharmacists are actively seeking the best infrastructures and workflows to address this readiness. For many, the best strategy starts with a front-end process improvement plan that lays the groundwork for a clean audit—and ultimately improves the outcomes potential for future requests.
While it may seem obvious, many resource-strapped pharmacies can be intimidated by the complexities associated with the Medicare Part B landscape. Strategic time and resource management is essential for front-end compliance. As such, pharmacies are increasingly leveraging partners to enable accurate and efficient documentation processes and achieve a worry-free audit.
Front-End Processes: Understanding the Impact
Pharmacies need to accurately complete the following documentation during front-end processes in order to maintain Medicare compliance:
• Detailed written order or prescription
Incoming physician orders and prescriptions require documentation of the start date, item description, dated physician signature, dosage, route of administration, frequency of use, dispense quantity and number of refills. If any of these items are missing, pharmacies must reach back out to a physician before sending a claim to Medicare to be compliant.
Pharmacies often fall out of compliance when claims are billed to Medicare with only a dispensing, verbal or transfer prescription order. Physician signatures—often illegible—can also be problematic, and lack of substantiating evidence proving that a signature belongs to a particular physician can result in non-compliance.
• Proof of delivery/pickup slip
Pharmacies are required to prove a patient received intended medications. When prescriptions are picked up, for example, correct documentation must include: the beneficiary’s name and signature, date of receipt, address and quantity. Shipped medications must have additional documentation including: a sufficiently-detailed item description, an identification number linking pharmacy documents with delivery service documents (e.g. a package or invoice number) and evidence of delivery.
Pharmacies can also be out of compliance for Medicare claims if the dispensing date of the medication does not match the pick-up date, or if a patient fails to sign their prescription pick-up slip.
• Refill request
Documentation of refill requests must be complete with each of the following elements in order to be considered compliant and include the following: the beneficiary name or authorized representative, item description, date of request, quantity of previous prescription still in a patient’s possession (consumable medications) and an assessment of functionality or dysfunction (non-consumable items).
A Better Front-End Strategy
Leveraging a strong partner is a simple step pharmacies can take to improve front-end Medicare compliance. Leveraging solutions that automate the capture and management of necessary information can help minimize draws on internal resources and flag issues, like illegible signatures or incomplete documentation.
Today’s pharmacies are likely to see increased audit activity. Having the right systems in place to ensure all necessary elements are present for a clean, compliant audit goes a long way towards placing pharmacies in a favorable light with Medicare.
Deborah Roberts is Change Healthcare’s Manager Recovery and Audit, CMS Compliance.
NACDS rolls out initiative to improve immunization rates
ARLINGTON, Va. — The National Association of Chain Drug Stores is launching three demonstration projects that aim to foster health care collaboration and increase pharmacy-based immunizations.
The goals of the project are for chosen healthcare entities to work together to develop and implement a value-based payment model that is scalable and replicable, and that results in improved immunization rates for a targeted population that are recorded in the appropriate state-based registry.
The models also will feature innovative methods for sharing immunization information among the participating health plans or systems, accountable care organizations, community pharmacies and patients. The awardees also will collaborate with public health agencies to improve pandemic vaccine preparedness.
“Legislators and regulators at the federal and state levels often reference pharmacists’ success in promoting the necessity of vaccines, and in increasing access to them,” said NACDS President and CEO Steven C. Anderson, IOM, CAE. “These demonstration projects seek to improve patient health by aligning the interests of healthcare partners which should increase immunizations and improve the healthcare outcomes of patients across the country.”
NACDS released a request for proposals in February 2016 seeking proposals that align interests across healthcare stakeholders to drive immunization rates. NACDS received more than 20 proposals and convened an independent review committee comprised of experts in the fields of public health, pharmacy operations, and healthcare quality.
To develop the demonstration projects: (1) The University of Pittsburgh will partner with Giant Eagle and the University of Pittsburgh Health Plan; (2) the University of Nebraska Medical Center will partner with Hy-Vee, the Nebraska Health Network and the University of Iowa Health Alliance; and (3) the University of Washington will partner with Bartell and QFC and the Washington State Health Care Authority to develop the demonstration projects.
The demonstration projects aim to fulfill the goals of an $800,000 Centers for Disease Control and Prevention (CDC) grant to NACDS, which examines innovative healthcare collaborations designed to demonstrate increased rates of pharmacy-based immunizations including influenza, pneumococcal, pertussis and herpes zoster. The grant also focuses on improving pandemic planning among pharmacies and state health departments, in addition to improving access to HPV vaccine resources and education for pharmacists.
AmerisourceBergen adds resources to support independent pharmacies
LAS VEGAS – AmerisourceBergen is launching several new programs to help independent pharmacies improve business performance while meeting growing patient need.
“At AmerisourceBergen, we are championing the independent pharmacist,” said president of Good Neighbor Pharmacy, Brian Nightengale, RPh, Ph.D. “Whether it is hearing feedback from our customers about how to improve their buying experience or delivering new solutions to enhance business profitability and patient care, we are fully committed to supporting the success of independently owned community pharmacies.”
The company highlighted the new solutions at ThoughtSpot 2016, Good Neighbor Pharmacy’s annual trade show, in Las Vegas. AmerisourceBergen leaders highlighted solutions designed to drive improved results across the entire pharmacy – from front-end sales to back-end operational performance.
• Advocacy Resources: As part of AmerisourceBergen’s ongoing support for independents, the company has added a new resource, OurIndependentVoice.com. The newly launched website provides pharmacists a centralized place to access tools and resources to join advocacy movements that impact care in the community setting, research policies impacting independent pharmacy, access letter templates and write to legislators, and connect with other pharmacists and pharmacy organizations.
• Specialty at Retail: The rapid growth of specialty products provides a natural intersection for community pharmacy to provide personalized patient care in complex therapies. These specialty products often have a high burden of administrative tasks that can be challenging for an independent pharmacy to operationalize economically. AmerisourceBergen is developing a specialty at retail program that will allow member pharmacies to better service patient needs while diversifying revenue streams. Through this program, independent pharmacies will be able to focus more on patient care instead of spending time and resources navigating administrative tasks.
• Front-End Retail Excellence: Good Neighbor Pharmacy is offering its members comprehensive services to optimize front-end sales, including access to business coaching, manufacturer promotions, point of sale (POS) data and reporting tools, and Retail Remedy, a monthly publication with news, tips, and product specials focused on retail strategies. While at ThoughtSpot 2016, many pharmacists joined an all-day front-end profit building seminar presented by the National Community Pharmacists Association (NCPA) and sponsored by Good Neighbor Pharmacy. This session kicked off a new five-year partnership to provide similar learning opportunities in convenient settings for pharmacists.
• Generics Buying Enhancements: AmerisourceBergen has redesigned the generics buying experience to not only deliver competitive up-front prices, but to serve pharmacists differently based on the way that they want to buy.
New to ThoughtSpot this year was an Innovation & Technology Showcase. Throughout the conference, attendees could visit the showcase to learn more about:
• ABC Order, a new ordering platform developed with pharmacists for pharmacists. The platform is engineered to fit within the pharmacy workflow to enable effortless ordering, smarter inventory control, quicker access to data and simple issues resolution. The new platform will be made available to customers in 2017
• Best practices for medication therapy management (MTM) programs to manage adherence and patient communications, and working with Medicare
• How partners of AmerisourceBergen’s Pharmacy Services Administrative Organization (PSAO), Elevate Provider Network, implement technology solutions to support reimbursement discussions with payers, and improve MTM, adherence and reimbursement
Good Neighbor Pharmacy’s 2016 Pharmacy of the Year Award was announced during general session. HB Pharmacy from North Arlington, N.J. received the esteemed award for exemplifying what it means to be a Good Neighbor Pharmacy in their commitment to enhancing patient care and lives in local communities. Since Gaspar Bellitti opened HB Drugs in 1964, the family-owned pharmacy has remained committed to its innovative, patient-minded approach to care. Driven in part by his father’s ideals, owner John Bellitti has invested in technology solutions that enable the staff to spend more time with patients. Under his leadership, the pharmacy has adopted an integrated approach to patient care, operating with the core belief that a person’s health and wellness requires a collaborative effort among all healthcare practitioners.
Following the Pharmacy of the Year announcement, retired NASA astronauts and twin brothers Scott and Mark Kelly delivered the keynote address. The astronauts reflected on the experiences and lessons that shaped their perception of teamwork and leadership, discussed how they learned to face and overcome adversities and shared personal strategies for adapting to change.