Steps to Reduce the Risk of a PBM Audit

PBMs have tremendous power and are essentially accountable to no one. Capitol Hill is beginning to take notice of this and legislative changes will likely occur in the future. However, Congress moves at a glacier’s pace and so it will be several years before pharmacies start seeing legislative relief. Until then, pharmacies have to deal with PBMs as they are. PBMs have tremendous discretion in deciding which pharmacies they will allow in their network, which pharmacies will be denied re-enrollment, which pharmacies will be kicked out of the network…and which pharmacies to audit. This webinar will focus on audits. In particular, the webinar will discuss the “hot button” issues that trigger audits. These include: (i) billing pattern that is different from those of comparable pharmacies; (ii) changes in billing pattern; (iii) waivers and reductions in patient copayments; (iv) use of 1099 independent contractor marketing reps; (v) dispensing of large quantities of compounded drugs; and (vi) shipment of drugs via mail-order. This webinar will discuss steps that pharmacies can take to reduce the chances of being audited. Lastly, the webinar will discuss the steps that pharmacies should take to respond to PBM audits.