It’s the New Year...Usually a time for setting big goals, getting your team motivated, inspired and hopefully double checking that your pharmacy is set up for compliance. Back in October, new Medicare Part D changes took affect and gained the full support of Health and Human Services to uphold them. There have been more auditors than ever before enforcing these constantly changing regulations. It's starting to make the previous years seem like "the good ole days." To put you at ease about these new changes, here's your update to the 2014's Medicare Part D regulations.
Most time-consuming change of 2013...
If you haven't heard by now, the most tedious change in late 2013 was the OIG Exclusion verifications. Verifications have been expanded to OIG, as well as GSA (General Services Administration), to verify that all your vendors, employees and business associates do not show up on the exclusion list. What’s changed this year is this process used to be just an annual requirement by Medicare, but Express Scripts, in conjunction with Health and Human services, has made this a monthly requirement. This means you must go to the OIG and GSA websites, type in your vendors, employees and business associate information and confirm that no one shows up every single month! To add to that, these websites only let you do a few entities and individuals at a time.
Fortunately, we've created an automated process to do this through the Compliance Portal™. It takes approximately 20 seconds once you have all the information in. This process meets your Medicare Part C, which is your advantage program, and Medicare Part D requirements, which is your drug program for Seniors.
No pharmacy is safe from inspection...
Continuing on from 2013, the Part D auditors either from the PBMs or Medicare Part D plans, now have ability to come into your pharmacy and validate that these certifications are being completed. In the past, all that pharmacies had to do was certify that they completed it and that was that. No one was coming to double check your records in your pharmacy. In 2014, this has changed.
Now, they are coming into your pharmacy to review your documentation.
Here are the 3 items you need in place right away:
- Have training records, training certificates and training logs for all your staff and document they have been completed every year.
- Have the new HIPAA program in place...they've tasked auditors to specifically make sure that your independent pharmacy has a new HIPAA program. Auditors can tell if you have a new program because if your Notice of Privacy Practice has a date prior to 2013, you have not updated your program. Everything changed in 2013 and went into enforcement on September 23, 2013. Click here to see the 4 key documents you need for HIPAA compliance in 2014.
- Third, you need to be able to prove that you’ve been doing monthly OIG verifications. Like I mentioned before, the monthly verification involves either going into the OIG website or GSA’s website and typing in all the names and businesses and coming out with printed reports for each name/business. Or you can again use the automated system that we have within the Compliance Portal™ which will process everything and print out a report in 20 seconds. Our database is updated as soon as the GSA and Office of Inspector General update their database.
As long as you follow these simple steps, whether an auditor comes in or not, you will be fully compliant and there will be no problems, no issues and no fines.
However, if they come in and do an audit and you failed to comply with all these items or if you fudge it and say you did it but you actually didn’t, these auditors now have the ability to pull all your Medicare Part C and Part D reimbursements which can be anywhere from 40 - 100% of your prescriptions for that year.
This could be very devastating. Most independent pharmacies would not be able to survive a penalty like this thus it's extremely important your OIG and GSA checks are completed properly every single month. We’ve made our system as simple as possible so I encourage you all try it out.
