Inside: Don’t put them off. Here’s what your independent pharmacy needs to know about the annual Medicare attestation and training requirements.
If your pharmacy accepts Medicare payments, then you’ve likely submitted attestations before.
While it’s easy to blow these off as unimportant administrative work, completing them can protect your business. Make sure you complete the requirements for the Medicare attestation. And, ensure each of your employees finishes the mandatory training.
“Pharmacies are contractually obligated to do this,” said Joshua Potter, Director of Compliance Services at PRS Pharmacy Services. “If they find out that you haven’t trained your employees, the PBMs and Medicare can claw back that money.”
What is a Medicare attestation?
A Medicare attestation is a legally binding verification that the pharmacy has met requirements set by the Centers for Medicare & Medicaid Services (CMS). CMS has given many pharmacy benefits managers (PBMs) the authority to oversee and enforce these guidelines.
PBMs typically send the requests for attestation directly to the pharmacy or to the pharmacy services administration organization (PSAO). Pharmacies can expect to receive requests for attestations from all Medicare prescription drug plans and Medicare Advantage plans they’re contracted with. These typically get issued in the fall, and pharmacies need to complete them by the end of the year.
Understanding the requirements
The main part of the Medicare attestation is verifying that all employees have completed the annual trainings set by CMS.
“Think of the attestation as what the pharmacy must do,” Potter said. “The trainings are what employees need to do. But when you do the Medicare attestation, you’re attesting that the employee has done something when it comes to the training.”
All employees directly or indirectly involved with the administration or delivery of the Medicare Part D prescription drug benefit must participate.
Employees who need to complete the Medicare attestation:
- Pharmacists
- Managers
- Pharmacy technicians
Every employee must complete the Combatting Medicare Part C and D Fraud, Waste, and Abuse Training and the Medicare Part C and D General Compliance Training.
While the trainings don’t have a set deadline, all employees must complete them annually. “As long as the employee is trained at least once a year, you’re good to go,” Potter said.
You also need to make sure to train your new hires within 90 days of hire.
Pharmacies can incorporate these trainings into their existing programs, but they’re not allowed to alter the wording in any way. Also, make sure to keep documentation that proves your employees completed the training.
Why it matters
Recently, payers have started requesting that pharmacies complete the attestations on NCPDP’s website instead of on their individual websites.
“It is important that the pharmacies do this, that they do pay attention to it, that they don’t just attest to it if they’re not doing it,” Potter said. “Because in the end, a pharmacy that has been compliant with these is protecting itself going forward.”
For help with attestations, contact your PSAO, pharmacy consultant, healthcare lawyer, or compliance services company.
What’s Included?
Medicare attestations include the following standard and new elements.
Code of Conduct
This part of the attestation asks if the pharmacy has a code of conduct in place to comply with the Prescription Drug Benefit Manual Chapter 9 Compliance Program Guidelines. A code of conduct is a simplified version
of the pharmacy’s policies and procedures.
Conflicts of Interest Screening
Some payers require pharmacies to screen their pharmacy employees for conflicts of interest. This includes employees, management, board members, directors, and other individuals. This screening checks to make sure pharmacies aren’t steering patients or doctors in a way that could harm the beneficiary.
Cultural Competency
Some payers are starting to request that pharmacies complete cultural competency training. This training seeks to better accommodate diverse patient populations. The training can include topics like the value of diversity, expanding cultural knowledge, adapting services and care to meet culturally unique needs, and helping patients with linguistic needs.
Dual-Eligible Beneficiaries
Payers in certain states require pharmacies to attest to completing their training on dual-eligible beneficiaries. Dual-eligible beneficiaries are those who qualify for Medicare and Medicaid.
Exclusion List Checks
Pharmacies have to check their employees on the SAM (Systems for Award Management) exclusion list and the OIG List of Excluded Individuals and Entities every month. These federal databases determine if your employees are eligible to work with Medicare and Medicaid. Also, keep a record of your checks. You can do a screen print out from the website or keep a log indicating when you did the checks.
Maintaining Records
Pharmacies must attest that they maintain all Medicare Part D records for a minimum of 10 years.
Records pharmacies must maintain include:
- Purchase records
- Invoices from wholesalers
- Employee trainings
- Hard copies of the prescriptions (physical or electronic)
- Proof that the patient picked up the medication or received the medication
- Documentation that the pharmacist provided counseling
Offshore Vendors
Some payers are asking pharmacies to attest if they’re using any offshore vendors. The attestation asks pharmacies to verify that those contractors or companies outside the U.S. are maintaining the security of protected health information (PHI) in compliance with the Health Insurance Portability and Accountability Act (HIPAA).
Training
Every employee must complete the Combatting Medicare Part C and D Fraud, Waste, and Abuse Training and the Medicare Part C and D General Compliance Training. While the trainings don’t have a set deadline, all employees must complete them annually.
Source: PRS Pharmacy Services
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