Audit Risks: Medication Home Delivery
Many independent pharmacies offer unique services to their patients, such as house charge accounts and medication delivery, to provide a better customer experience. While these are convenient services to offer patients, they do bring audit risks if they are implemented without appropriate safeguards.
PAAS National® analyst have seen numerous PBM audit recoupments for insufficient deliveries and discrepancies linked to insufficient evidence of refill request, copay collection, or delivery. Additionally, we have seen audits where the prescriptions were billed for deceased patients.
Review the tips below to ensure that your pharmacy doesn’t incur unnecessary audit risks.
PAAS Tips:
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- Home delivery tips
- Require a dated signature from patient/caregiver at every delivery (pre-printed dates on delivery manifests are insufficient)Avoid leaving medications in the mailbox or at the door without evidence of delivery (geotagged photos from pharmacy staff are typically insufficient)Avoid “automatic refills” and instead implement a “medication synchronization” program that includes a telephone check-in prior to medication billing and delivery to ensure that patient is still alive, living at same address, has not been hospitalized since last delivery (or had medication therapy changes), and to confirm the needed medications prior to scheduled delivery date
- Collect payment at the time of delivery, or implement a robust accounts receivable (“house charge”) process
- Facility delivery tips
- Coordinate with LTC facilities to understand if Medicare patients are in a “Part A” versus a “Private Pay” status as this will dictate whether pharmacy is to bill the facility (if Part A) or Medicare Part D (if private pay)
- Develop written agreements in place that require facility cooperation with retroactive billing changes such as when claims are accidentally billed to Medicare Part D and then subsequently adjusted due to Part A status
- Pre-printed dates on delivery manifests are insufficient, receiving individuals should handwrite the date received
- Coordinate with LTC facilities to understand if Medicare patients are in a “Part A” versus a “Private Pay” status as this will dictate whether pharmacy is to bill the facility (if Part A) or Medicare Part D (if private pay)
- Additional helpful information on house charge accounts can be found in the following Newsline articles:
- January 2024, Staying Compliant with House Charge Accounts
- April 2024, Required: Proof of Patient Copay Collection
I obtained my PharmD from the University of Wisconsin-Madison School of Pharmacy and worked for a major chain as well as various LTC and independent pharmacies, before coming to PAAS.
I am passionate about learning and teaching. I strive to learn something new about PBM audits every day, so that PAAS can be more knowledgeable to better serve our members! In 2018, I started traveling to state pharmacy conferences to present audit seminars and meet our wonderful members in person.
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