Best Practices for Vaccine Documentation

Without question, vaccine claims are on the rise! Consequently, PAAS National® analysts have recently seen an increased number of PBM audits for these claims. Consider a few best practices to reduce your risk of audit recoupments:

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Billing

Quantity – Submit the correct NCPDP billing unit of each (EA) or milliliter (mL) based on vaccine product

Day Supply – NCPDP recommends that all vaccine claims be submitted as a 1-day supply

Origin Code

  • Submit the origin code in accordance with how you received the prescription
    • 1 – written, prescription obtained via paper.
    • 2 – telephone, prescription obtained via oral instructions or interactive voice response using a phone.
    • 3 – electronic, prescription obtained via SCRIPT or HL7 Standard transactions, or electronically within closed systems.
    • 4 – facsimile, prescription obtained via transmission use a fax machine.
    • 5 – pharmacy, this value is used to cover any situation where a new Rx number needs to be created from an existing valid prescription such as traditional transfers, intrachain transfers, file buys, software upgrades/migrations, and any reason necessary to “give it a new number. This value is also the appropriate value for “Pharmacy dispensing” when applicable such as BTC (behind the counter), Plan B, established protocols, pharmacists’ authority to prescribe, etc.
  • Note that codes 1-4 represent patient-specific prescriptions while code 5 covers various other situations

Prescriber ID

  • Submit the NPI of the prescriber
  • This would be the prescriber of a patient-specific prescription or standing protocol
  • This would be the pharmacist Type 1 NPI (individual) as per state law where pharmacists have prescribing authority or when ordered under PREP Act declaration during COVID-19 pandemic

Documentation

Item Comments Requested in audits
Authority to Administer
  • You may have a patient-specific prescription with all elements required by state law
  • You may have a standing protocol or collaborative practice agreement
  • For situations where you are administering pursuant to a protocol, CPA or PREP Act declaration, PAAS recommends creating a “placeholder prescription” with all normal prescription elements for your files
 Yes
Screening Checklist Not requested by PBMs, however should retain for your records No
Vaccine Administration Record (VAR) Must document every administration (required by law)

Include at least the following:

  1. Date of administration
  2. Vaccine manufacturer
  3. Vaccine lot number and expiration date
  4. Site of injection
  5. Name and title of the person who administered the vaccine
  6. Vaccine information statement (VIS) or EUA Fact Sheet
    • Date printed on the VIS
    • Date the VIS was given to the patient or parent/guardian
 Yes
VIS or EUA Fact Sheet Most current version must be provided prior to each administration (required by law) No

PAAS Tips:

  • Common errors found during audits are wrong quantity billed and missing VAR documentation
  • See CDC website or org for sample forms and additional resources
Eric Hartkopf, PharmD
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