April 2023 - Newsletter

Included in this newsletter

Tips for Managing your DIR fees

Here are a few tips to help you manage and control your DIR fees. By working hard to get them under control now, you will be setting yourself up for a more profitable future.

• Identify your Patients
  • There are a few different tools that you can use to help identify what patients are the best fit to help you increase your revenue and potentially decrease your DIR fees. Use the following to help you identify your patients:
    • Your computer software (Liberty or PioneerRx)
    • Multiple Medication Patients (starting with the highest and working down)
    • EQuIPP Outliers
    • MTM Vendors
    • Provider Referrals

• Monitor EQuIPP
  • Be sure to keep an eye on your EQuIPP scores to get the best handle on your stores DIR fees. By monitoring your EQuIPP scores, you are able to work to maintain your star rating which in turn will help you potentially recoup or lessen your DIR fees. Our pharmacies that are closely monitoring their scores and making sure their star ratings are where they need to be, are paying the lowest rates and are often times receiving most if not all of the DIR fees they are paying out back at the end of the year.

• Medication Adherence
  • Check out the. Pharmacy Compliance Package – Chapter 8 – Medication Adherence.  There are a lot of great resources on how to get your Medication Adherence Program growing or if you don’t have one, these P&Ps will help you get it started.

• Complete MTM Cases
  • This is where you make your money. Some owners take them home or do them whenever it is most convenient for them (at home, after they put the kids to bed, etc.). On a low average, you are able to make $2/minute or $120/hour. Can you afford not to do them?

• Effective Conversations
  • Train your techs to listen for verbal cues from your patients that may indicate that they would be ideal to talk to about additional services your pharmacy may provide.
    • Self- Monitoring Blood Pressure Service
    • Chronic Disease Self-Management Program
    • Vaccine Screenings and Referrals
    • Medication Adherence
    • COVID Vaccines and Screenings
    • Diabetic Care Management
    • CBD and Supplements

Enforcement

• Union County pharmacy must pay $226,000 for Medicare/Medicaid scam: NC Attorney General

Independent Pharmacy Growth from Chain Staffing Issues

Several of our clients has seen a steady incline in customers over the past year due for various reasons with the large chains. One instance is a pharmacy that has been steadily gaining patients and popularity due to staffing issues at one of the local major chains.. Because of these issues with the chain, the local community has begun to back her independent pharmacy and become familiar with the services and level of service that they can offer. With the lack of patient care with the chain pharmacies, the local communities are being directly impacted. At this pharmacy in particular,  the local newspaper decided to cover the event and interview the pharmacy owner to help serve the local community. This then caused a great increase in scripts for the store. Just last month she was up almost 31 new scripts per day or 3-4 patients.

Is there something like this affecting your community? Could you benefit from connecting with the local newspaper or radio station to promote your services?

• Independent Pharmacy Growing from Walgreens Understaffing

Expiration of the Public Health Emergency for COVID-19

May 11, 2023, is the official expiration date of the Public Health Emergency for the COVID-19 pandemic.  All waivers, extensions, and temporary CLIA & immunization PTANs will also expire.  We request a review of any pandemic processes added to your operations.  We believe our clients no longer have a temporary PTAN for immunizations and CLIA waivers.  Contact your Project Manager if you only have a temporary Medicare PTAN.  We expect confusion because the Department of Health and Human Services (HHS) and the Centers for Medicare and Medicaid Services (CMS) have not addressed a number of items.

Preparing for the Drug Supply Chain Security Act (DSCSA) Implementation

On November 27, 2023, the DSCSA (track & trace) is going into effect. 

Some pharmacy software companies are beginning to prepare their software to run the DSCSA QR codes.  Still, there has only been one successful test of the entire DSCSA requirement, and it was between AmerisourceBergen and RxScan.

We are working with RxScan to assist in writing a policy and procedure and supporting documents, which will be on their website at no cost.  RxScan software will work with any pharmacy system; the fee is $365.00 yearly.  Please take some time to review their website:  https://www.rxscan.com.

R.J. Hedges & Associates Brokerage and Valuation Services

Did you know we can also provide our compliance customers with assistance for Business & Pharmacy Valuations, Business Brokerage (Acquisitions & Mergers), Representation during acquisition sales, and Business Management Consulting? Please talk to your Project Manager to get more information.  With many pharmacy owners looking to buy or sell their pharmacies, having an expert guide you through the process makes navigating those waters much easier.  Check our our Brokerage page for more details.   https://www.rjhedges.com/pharmacy-brokerage

Reminder about COVID-19  Vaccine Reconciliation

Pharmacies that received COVID vaccine purchased by the federal government should be sure to reconcile the disposition of all doses.  Reported doses are given + reported doses wasted + doses remaining in stock should equal the total number of doses received.  Don't be concerned if the number of doses wasted seems high.  That is expected.  The important thing is that all your doses are accounted for in your reporting.  Work with the entity through which you received your vaccine, whether it be a federal partner or your state, if you have questions.  Source: NCPA

Changes to Continuous Glucose Monitors (CGMs)

CMS changed the HCPCS codes for Continuous Glucose Monitors (CGM) effective 04/16/2023.  Glucose Monitors Local Coverage Determination

The following codes are being deleted:

• K0553 and K0553 KF from the DMEPOS fee schedule file and cross-walked to new code and modifier combinations A4239 and A4239 KF.
• K0554 and K0554 KF from the DMEPOS fee schedule file and cross-walked to new code and modifier combinations E2103 and E2103 KF.

The following codes are the replacement HCPCS codes for CGMs:

• Additionally, the code descriptors for adjunctive CGM codes A4238 and E2102 are revised to add "non-implanted" to clarify use with no associated changes to the Class III code/modifier KF fee schedule amounts on the DMEPOS fee schedule file:
  • A4238 - Supply allowance for adjunctive, non-implanted continuous glucose monitor (CGM), includes all supplies and accessories, one month supply = 1 unit of service
  • E2102 - Adjunctive, non-implanted continuous glucose monitor or receiver.

401K Plan Options

The federal government is trying to increase company participation with 401K plans for their employees.  We started the RJ Hedges Multiple Employer Plan (MEP) a few years ago and are fully set up now.  All fees for the first three years are full tax credits.  There are three options for our clients:

1. Start a new 401K under the MEP.  Documentation and plan development has never been easier.
2. If you already have a 401K plan, you can transfer your 401K plan into our MEP.  In a group plan, the annual fees will reduce because of the power of the overall assets.
3. If you have a SimpleIRA, you cannot enter into a 401K plan until January 1, 2024.  However, you can start planning now for the transition.  There are a couple of requirements that would need to be completed in advance of January 1st.  The bonus is the owners can put a lot more into a 401K than a SimpleIRA.

Contact your Project Manager for more information and the 401K team will begin a discussion with you.

R.J. Hedges Bulletin Releases/Webinars

The following items can be accessed through the Message Center on the Compliance Portal®:

• April Task List (04/01/2023)

New and Updated Forms

• DMEPOS
  • Glucose Monitors & Supplies Detailed Product Descriptions
• OSHA
  • Facility Safety Checklist

New and Updated Policies and Procedures

• DMEPOS
  • General Equipment Cleaning and Storage
  • General Equipment Delivery and Setup
  • Record Retention
• DEA and Pharmacy
  • Pseudoephedrine Program
• HIPAA
  • Right of an Individual to Request Restriction of Uses and Disclosures
• Human Resources
  • Substance Abuse Training

Updated Plans

Note: Project Managers are contacting their clients individually so the correct information can be entered or edited. On-going through April 2023)

• HIPAA Compliance
  • Disaster Recovery Plan
  • Risk Analysis
  • Risk Management Plan
• OSHA Compliance
  • Bloodborne Pathogen Control Plan

Note:  Project Managers are contacting their clients individually so the correct information can be entered or edited.  On-going through April 2023