Update to PAAS’ Onsite Credentialing Guidelines

PAAS National^® has created an Onsite Credentialing Guidelines, an extensive checklist to assist PAAS members with scheduled and/or unexpected visits from PBM auditors. Unannounced visits can catch pharmacy staff off guard when the Pharmacist-in-Charge (PIC) is not present. Be sure you are reviewing and advising your staff on the information included on this checklist so they are prepared.

There was an 11% increase in reported onsite audits over the past two years. PAAS takes pride in staying up to date on ever changing trends in pharmacy. Keeping our members informed on PBM inquiries during the credentialing process, or an onsite visit, is one of our priorities. We recently added the following updates to our Onsite Credentialing Guidelines:

• Emergency Supply – Federal law requires Medicaid to provide at least a 72-hour supply of a covered drug to Medicaid patients in an emergency situation when prior authorization is pending as per 42 US Code 1396r-8(d)(5)(B). Pharmacists should use their professional judgement regarding whether there is an immediate need. See your state Medicaid agency for details on billing “emergency supply”.
• Out of Stock Medication – Pharmacies must develop and follow procedures to ensure patients have timely access to prescribed medications. This may include ordering medication for next business day, transferring prescription to another pharmacy or contacting prescriber to obtain a prescription for an alternative therapy.
• CMS 10147 – As of January 1, 2023, pharmacies must also include a Multi-Language Insert pursuant to CY 2023 Medicare Advantage and Part D Final Rule (CMS-4192-F) published May 9, 2022. There is no requirement for pharmacies to document the distribution of the notice. Auditors may confirm that pharmacies are distributing the current version of the CMS 10147 and multi-language insert to beneficiaries. PAAS Audit Assistance members can see this month’s Newsline article, Multi-Language Insert Must Be Provided to Medicare Beneficiaries as of January 1, 2023.

Interested in having a customized FWA/HIPAA Compliance program? Contact PAAS to get started today! info@paasnational.com or 608-873-1342.