Ensuring Audit Readiness: What PBMs Look for in Signature Logs and Proof of Delivery
One of the most common questions PAAS National® receives from our members is: what are the requirements for audits when signature logs are requested. This article contains reminders and requirements auditors will be looking for to help ensure your pharmacy will be prepared.
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With the end of the Public Health Emergency on May 11, 2023, PBM waivers were rescinded regarding signature collection and mailing allowances, except for Humana who permitted the mailing waiver until December 31, 2023. Pharmacies must remind all staff to collect signatures at the time of prescription pickup and delivery. Not complying could result in big audit recoupments and lots of hassle for pharmacies to appeal.
Pharmacies and patients alike became used to not having to sign at prescription pick up, or like the convenience of having their local pharmacy mail or deliver medications to them. Unfortunately, getting patients to understand what their insurance requires can be difficult, but is necessary.
The large PBMs like Caremark, Humana, OptumRx and Express Scripts allow delivery of prescriptions, but some do have limitations or restrictions. Some PBMs may include these restrictions in their pharmacy contract agreements and not their provider manuals.
Two of the largest PBMs restrict delivery as follows:
- OptumRx® Pharmacy Provider Manual specifically states deliveries can only be done by a pharmacy’s W-2 employee within a 100-mile radius. The use of common carriers, including USPS are prohibited by this PBM.
- Caremark® Pharmacy Provider Manual states pharmacies that deliver greater than 20% of monthly claims by common carriers, including USPS, are not considered “Retail Pharmacies”.
PAAS Tips:
- Remind all staff that signatures are now required for all in-store pick-up and delivered prescriptions
- Signature logs, delivery logs, and tracking must include the date the patient received the prescription
- Pharmacy staff and delivery drivers are not allowed to sign on behalf of a patient
- Pictures showing delivery was made, or patient “authorization” to leave at their door is not acceptable for PBM audits
- When utilizing a common carrier, the PBM requires a link between the prescription and the tracking
- Tracking information is required for audit purposes, so be sure you have access to this information after deliveries have been made
- Pharmacies that mail or ship prescriptions out of state must adhere to the receiving state’s licensure requirements
- PAAS has additional resources available on our website, including Signature Log Book to be Printed and our Signature Trifold Mailer
I attended Madison College in nearby Madison, WI (PAAS headquarters are in the Madison suburb of Stoughton). Prior to coming to work at PAAS, I worked as a Certified Pharmacy Technician in a retail setting for 25+ years. Pharmacy has been my life’s work.
Helping our members have a successful audit experience is very rewarding. Celebrating with them, when PAAS often helps generate positive post-audit results, is the best part of my work.
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