Does My Pharmacy Really Need Cultural Competency Training?

Pharmacies are no stranger to the requirements of completing annual Medicare Fraud, Waste, and Abuse training, which is a very clear requirement created by Medicare Part D and MAPD statutes. Because CMS holds PDPs and MAPDs responsible, PBMs often ask for the pharmacy’s FWA training during onsite audits. On the contrary, cultural competency training isn’t something PBMs regularly ask for. In a world where pharmacy employees are already spread thin, is completing cultural competency training truly necessary?

As of April 2021, NCPDP required pharmacies to indicate if they train their staff on cultural competency and maintain evidence of such training, when going through the pharmacy’s annual NCPDP profile credentialing. Since adding this question, PBMs have decreased the number of direct attestations required of community pharmacies. However, indicating ‘no’ in NCPDP is not without potential repercussions as PBMs may exclude you from provider listings of culturally competent care, as this was required for Medicaid managed care plan directories. Additionally, there are federal requirements that have been in place for many decades.

Through many federal laws and regulations related to discrimination and cultural competence comes the requirement that all healthcare professionals, including pharmacies, must take “reasonable steps” to provide equal access to care across all patient populations. It cannot be expected that a pharmacy would be able to meet the standards if there is a lack of knowledge on what the legal requirements are or what is expected of your pharmacy staff to meet these federal regulations. For this reason alone, training your staff on cultural competency is a must.

In addition, there have been real world examples of pharmacies being subpoenaed and sanctions being placed on pharmacies due to the Department of Justice (DOJ) determining there was a lack of “reasonable steps” being taken to ensure equal access to care, one being Rite Aid. In November 2021, the Justice Department and the U.S. Attorney’s Office for the Middle District of Pennsylvania reached a settlement agreement with Rite Aid Corporation in the matter of people with disabilities having difficulty accessing information about the COVID-19 vaccinations and booking vaccination appointments online. Specifically, Rite Aid’s COVID-19 registration portal was not compatible with screen reader software used by some patients with disabilities. In addition, those who have issues using a mouse were unable to use the tab key in its place when filling out the consent form. Therefore, it was determined there was not equal access to care and Rite Aid had 30 days to correct their online COVID-19 vaccine content to industry guidelines that allows accessibility for users with disabilities. In addition, Rite Aid was ordered to regularly test and correct any issues with its COVID-19 Registration Portal for a 30-month duration.

PAAS National^® understands that your time is valuable. Therefore, we condensed more than three hours of content into (less than) one hour of training, making it practical and tailored to the independent pharmacy setting. Our efficient training covers federal requirements, including linguistically appropriate services, and concludes with a certificate of completion.

PAAS Tips:

• Make sure your NCPDP profile is up to date! PBMs now utilize the pharmacy’s NCPDP profile to pull information in regard to cultural competency training instead of having pharmacies directly attest to each individual PBM.
  • Humana still requires a direct attestation and additional training in select states
• Watch our On-Demand Webinar “Does My Pharmacy Really Need Cultural Competency Training?”