Responding to PBM Re-Enrollment Applications, Request for Information and Contract Terminations
PBMs are integral to the pharmacy’s existence. The power possessed by PBMs is frustrating and unsettling. Nevertheless, it is reality. Particularly with the increase in the number of compounding pharmacies, PBMs are more intrusive and demanding than they have been in the past. This program will discuss the ways that PBMs are intruding on pharmacies. Examples are detailed re-enrollment/re-credentialing applications, requests for information pertaining to waiver/reduction of copayments, audits of claims, and termination of contracts. Equally as important, the program presents practical steps to completing re-enrollment/re-credentialing applications, responding to requests for information, responding to billing audits, and responding to a termination notice.WATCH ON DEMAND
Arrangements Between Pharmacies and Long Term Care Facilities: Landmines to Avoid
Let’s look at a comparison. Medicare “grew up with” 23 million of the Greatest Generation (World War II generation). We now have 78 million Baby Boomers who are retiring at the rate of 10,000 per day. With such a large aging population, utilization of long term care facilities will increase dramatically. This program will discuss how a pharmacy can properly enter into arrangements with skilled nursing facilities (“SNFs”) and custodial care facilities.
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Legal Guidelines for Waiver or Reduction of Medicare and Commercial Co-Payments
Pharmacies have an obligation to take reasonable steps to collect co-payments from Medicare beneficiaries. From the viewpoint of the OIG, it is important for the beneficiary to pay something. This causes the beneficiary to have “equity” in the process thereby making the beneficiary a wiser consumer of health care products and services. When a pharmacy routinely waives co-payments for Medicare beneficiaries … and particularly when the pharmacy advertises that it waives co-payments, then the OIG considers this to be a kickback, inducement, and a false claim. According to the OIG, the pharmacy can only waive a co-payment when the pharmacy has made a patient-specific decision to waive…..and that decision is based on the financial condition of the patient. Contracts with commercial insurers and state statutes impose substantially the same requirements on pharmacies that bill commercial insurers. In fact, PBMs are kicking pharmacies out of network when the PBMs conclude that the pharmacies are routinely waiving co-payments. This program will discuss the requirements imposed upon pharmacies to attempt to collect co-payments from Medicare beneficiaries and commercial patients, and the steps that the pharmacy should take before waiving a co-payment.
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Compounding Pharmacies: Steps To Avoid Issues with the FDA, DEA, Pharmacy Boards, and Patent Holders
In light of the New England Compounding Center tragedy, the state boards are becoming more assertive and the jurisdictional powers of the FDA have increased. This program will discuss the rules and regulations that compounding pharmacies must currently follow. This program will “gaze into the crystal ball” and discuss the additional regulatory actions that will take place in the not-too-distant future. Separate and apart from governmental regulation, this program will discuss the rights of manufacturers that own drug patents and steps that the compounding pharmacy can take to avoid litigation from a manufacturer to enforce its patent rights.WATCH ON DEMAND
Purchasing a Pharmacy: State Lincense, DEA Permit, Medicaid Number, The NCPDP, and Other Regulatory Issues
When purchasing a pharmacy pursuant to an “asset sale,” there are a number of steps that must be fulfilled. The purchaser must obtain its own pharmacy license; until it does so, it can operate under the seller’s pharmacy license pursuant to a power of attorney. This program will discuss the many regulatory requirements that must be met in an asset purchase and the fewer regulatory requirements that must be met in a stock purchase.
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As the prescription drug market becomes more sophisticated, patients, PhRMA and payers will rely more on the expertise of a community pharmacist. Consequently, the pharmacists must also continue to evolve in order to remain competitive and service biological products as well as be familiar with a rapidly changing reimbursement environment. You will learn the following in this presentation:
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Prevention is Key: Steps to Prepare for and Respond to an FDA Inspection or Enforcement Action
Join us for this webinar as we answer your questions about an FDA Inspection. This webinar will include a discussion on the legal basis of where the FDA can assert jurisdiction over pharmacies, an outline of steps that the pharmacy can take to prepare for an FDA inspection, the steps that the FDA follows in conducting an inspection, and laying out the steps that the pharmacy can take to respond to an FDA inspection/enforcement action.WATCH ON DEMAND
Listen to the first webinar in our Pharmacy series. This webinar covers topics on: drug pricing and likely changes in 2017, compounded drug developments including increased government oversight of compounding pharmacies, The 21st Century Cures Act, Pharmacy Benefit Manager oversight of pharmacies in 2017.WATCH ON DEMAND