In the most recent Script newsletter, the California State Board of Pharmacy explained that it received multiple complaints and observed practices where non-pharmacist staff were initiating the immunization process. It reminded that the authority to independently initiate and administer a vaccination extends only to pharmacists. The Board strongly encouraged pharmacies, designated pharmacists-in-charge, and pharmacists to
When applying manufacturer’s coupons could get a pharmacy in trouble
It is not uncommon for pharmacies to apply manufacturer’s coupons to assist patients with high deductibles. But when applied incorrectly, the pharmacy may face recoupments, audits/investigations, and large settlements as recent cases illustrate.
The U.S. Attorney’s Office has recently reached a $3.5 million settlement with specialty pharmacy Advanced Care Scripts, Inc. (ACS), to resolve allegations
Importance of accurately reporting Usual and Customary Drug Prices
Recently, we have seen many cases filed by whistleblowers against pharmacies for not properly reporting their Usual-and-Customary Drug Prices (U&C). The cases are usually filed under the False Claims Act (FCA) for manipulating U&C to receive greater reimbursements from government payors.
First of all, what is U&C? There is no uniform definition. Instead, third-party payor
When pharmacy’s attempts to make money result in big trouble.
Due to low reimbursement rates, many pharmacies are struggling to maintain their profit margins. Some turn to specialty medications, some convert into veterinary pharmacies, and some close their doors to retail patients and start working with long-term care facilities. And there is a category of pharmacies that step into the murky waters of adjusting patient
Unverified licensure could cost your pharmacy millions of dollars
While this is not a new case, nevertheless it must be revisited to remind the importance of verifying all licensure, credentials, and records of pharmacy employees. This straightforward and easy step could potentially save pharmacies millions of dollars, as this case and many enforcement actions illustrate.
Earlier this year, Walgreens agreed to pay $7.5 million
Dispensing in Emergencies. When prescriber is not available.
Many prescribers’ offices are closed due to the coronavirus outbreak, leaving many pharmacies unable to obtain fill authorizations for patients.
Under California law, pharmacies may refill prescriptions without prescriber authorization if:
- the prescriber is unavailable to authorize the refill;
- in the pharmacist’s professional judgment, failure to refill the prescription might interrupt the patient’s ongoing
PBM audits of test strips purchases. Things to keep in mind: clawbacks and terminations.
Do you purchase test strips from suppliers authorized by manufacturers to distribute these products? If not, you may face significant chargebacks and contractual termination when PBMs audit your pharmacy’s test strips invoices.
Virtually all PBM require test strips to be purchased from the suppliers expressly authorized by manufacturers to distribute their products. Most PBM manuals
Should you notify PBMs of a (potential) disciplinary action?
Many pharmacies ask if they need to notify PBMs of a disciplinary action and if so, when? Many fear that PBMs may terminate their contracts with the pharmacy. As a result, only some end up providing notices, while some are terminated for failure to provide a timely notice of a disciplinary action.
If we look
Pharmacy Inspection Checklist
The California State Board of Pharmacy has published an inspection checklist to guide pharmacies on what to inspect during an inspection.
The brochure elaborates on the process to be followed by the inspector. For example, the inspector must provide the pharmacy with:
- a business card;
- a receipt for any records taken from the premises;
Greater risks under the False Claims Act
Last month, the U.S. Supreme Court extended the time in which a private party may bring a suit under the False Claims Act (FCA). The decision – United States ex rel. Hunt v. Cochise Consultancy – extended the statute of limitation to bring an FCA action up to 10 years from the date of the