Bowel Prep Kit Billing Under CMS Review: PBMs in Focus

1. Invalid quantity and unit of measure being used
   1. See the following chart below for proper NCPDP billing units on Bowel Prep Kits:

2. Incomplete Directions
   • Clarify “Use As Directed”, PAAS suggests contacting the prescriber to find out if the patient is to follow package directions or if the prescriber has directed the patient to take it in a different manner. The Pharmacy can also verify the directions if the patient has instruction sheets from the provider.
   • Once clarified, document a clinical note on the prescription and update the patient’s label with the specific directions or “Use as directed per package” and bill the appropriate day supply

3. Incorrect Days’ Supply
   • Bowel prep products for colonoscopy should be billed as 1- or 2-days supply, depending on dosing schedule
   • Be aware of the Beyond-Use Date on the chart above when considering the days’ supply
   • If the prescription instructions for use indicated chronic/maintenance dosing (e.g., 30 days or includes refills), clarify indication and confirm that there was no prescribing error (e.g., intended to prescriber Miralax)

PAAS Tips:

• Do not rely on the days’ supply field on e-prescriptions alone as it is often incorrect and would be insufficient for audit
• Dispensing technicians and verification pharmacists can help double check days’ supply with visibility on screen or printed “back tags”
• Consider performing small “self-audits” to spot check your team for accuracy and consistency