Reminder: Documents needed for a pharmacy audit

As a reminder, if your pharmacy is contacted to schedule an audit, you should keep the following  documentation requirements in mind. To ensure a smooth audit — and to avoid preventable findings —  be prepared to provide complete and accurate records.

Prescriptions. The pharmacy must furnish the original prescriptions for written and verbal orders, but may submit printed copies of electronic and faxed prescriptions. Scans of written and verbal prescriptions are not accepted. If the claim was submitted with a “compound 2” indicator, the pharmacy must also supply the compound record, including the national drug codes and the quantities used.

Dispensing histories. The pharmacy must provide a printout of the dispensing history of each prescription; i.e., the date of each dispense for the life of the prescription as well as the quantity dispensed. These can be listed on a printed spreadsheet or your pharmacy software may have a report. If your computer does not have this capacity, please record the dispensing history, including the quantities, on a photocopy or back of each prescription. Note:  If the medication, drug strength or quantity changed for any dispense, this information should also be documented.

Signature logs. All Blue Cross and Blue Care Network prescription drug programs require a signature from the member, their representative or their caregiver at the time of dispense to verify receipt of their medications. We accept a member’s, a representative’s or caregiver’s signature on a manual or electronic log, including signatures from drive-through customers, as proof that the member received the prescription. For prescriptions that pharmacies mail to members, the pharmacy should provide a dated “proof of delivery/receipt” signed by the member, their representative or their caregiver.

Members’ rights notice. Blue Cross is required to report to the Centers for Medicare & Medicaid Services whether network pharmacies are compliant with the requirement to give Medicare Part D patients a copy of the Medicare Prescription Drug Coverage and Your Rights Standardized Pharmacy Notice (CMS-10147/OMB 0938-0975) if the prescription cannot be filled. Please have this notice printed to show the auditor.

Record retention. As a reminder, the minimum time a pharmacy must keep prescription records for Blue Cross and Blue Care Network commercial is five years from the last date of service. Michigan   law requires that every prescription has to be preserved for at least five years. The federally administered Medicare plan requires that prescriptions be retained a minimum of 10 years after the last date of service.

If a pharmacy does not have the required documents as described above, monetarily recoverable findings may result.