Hoping that your community pharmacy won’t be audited is not a good business practice. Regular and correct maintenance of prescription records can mean the difference between extra expenses for your pharmacy and a problem-free audit.
To prevent future frustrations—and the loss of money—your pharmacy should maintain good recordkeeping and business practices. While the auditing entity will look at a range of documents, issues, and records, you can avoid major pitfalls in the future if your pharmacy is targeted for an audit by watching out for these five common audit discrepancies.
1. Not maintaining prescription hard copies
Maintaining accurate prescription records is critical to your business—especially if your pharmacy is the target of an audit. Pharmacies must maintain the hard copies of prescription records that patients bring in for up to five years after the prescription is dispensed depending on state and federal laws, or if the pharmacy is involved in an ongoing audit or investigation.
A good routine business practice is to file a prescription’s hard copy immediately once the prescription is dispensed so the hard copy doesn’t get lost or forgotten.
Also, some state laws require that call-in or faxed prescriptions be reduced to hard copy form with specific details such as that the hard copy must be signed and dated in ink. Know your pharmacy’s state laws and train your staff in the proper methods to maintain hard copies.
2. Filling unauthorized or not documenting prescription refills
Your pharmacy knows that refills must be clearly indicated by the prescriber, but just as important is maintaining documentation of prescription refills. Know your state and federal laws when it comes to refill orders called in by phone or faxed to your pharmacy. Without refill documentation, your pharmacy could be subject to a discrepant claim. Always remember to check the PBM’s Pharmacy Provider Manual for more information on filling unauthorized prescriptions and documenting refills.
3. Dispensing incorrect days supply
Your pharmacy must submit the quantity and days supply of a prescription based on the amount issued by the prescriber. If you issue a prescription greater than the documented days supply, you could face a chargeback. Check the PBM’s Pharmacy Provider Manual for more information on incorrect days supply.
4. Using incorrect DAW codes
Your pharmacy must maintain the correct dispense as written codes (DAW) according to the set NCPDP standards or the prescription claim could be labeled as a discrepant claim and go unpaid. Make it standard procedure in your pharmacy to double check that the correct DAW code is used based on the information on the prescription and the prescriber’s signature. Don’t forget to check the PBM’s Pharmacy Provider Manual for more information on DAW Codes.
5. Filling prescriptions that lack or contain inaccurate directions
Make sure to always include calculable, specific directions on every prescription dispensed based on the quantity issued by the prescriber. A “use as directed” prescription may be considered valid if the prescriber indicated a certain quantity and days supply within clinical reason. As always, check the PBM’s Pharmacy Provider Manual for more information on inaccurate directions.
Also keep in mind that Medicare Part D rules and regulations are different for keeping records and filling prescriptions. Check the Centers for Medicare and Medicaid Services for audit information, but always refer to the specific PBM’s Pharmacy Provider Manual.
