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Self-Audit Practices to Protect Yourself in Case of a Medicare Pharmacy Audit

 Posted on June 14, 2019 in Pharmacy License Defense

IL license lawyerThe world of healthcare is constantly changing. For some pharmacies, keeping up with these changes can be difficult, particularly for independent or small pharmacies. The Centers for Medicare and Medicaid Services (CMS) is the governing body that oversees the practices of different medical professionals who provide services covered by Medicare and Medicaid. One of the goals of CMS is to try to cut down on healthcare fraud and they do this by conducting audits to ensure providers operate within the legal standards. CMS audits can sometimes produce less-than-favorable results that could seriously affect the operation of your pharmacy and its financial wellbeing. Here are a few things you and your employees can do to minimize any errors or inadvertent fraudulent practices:

  • Ensure you are meeting requirements for both non-controlled and controlled substances. When filling and dispensing a prescription, there are certain pieces of information that you must collect, plus a few special pieces of information for controlled substances. To fill a prescription, you must have the prescriber’s signature on the prescription, the name, strength and dosage form of the drug, the directions for use and the number of pre-authorized refills (if any). For controlled substances, the prescriber must have the appropriate authority to prescribe such a drug and the prescriber must manually sign the prescription on the date it was issued.
  • Follow proper procedures for prescription dosages that exceed the Food and Drug Administration (FDA) guidelines. If you or your employees notice that a drug has been prescribed an unusually high dosage or in a dosage that exceeds the FDA’s recommendations, you should first check the drug’s dosage guidelines on one of the online references. If the dosage does, in fact, exceed FDA guidelines, you should contact the prescriber to verify the dosage amount. Be sure to get a hard copy of all communication regarding dosage and include the patient’s diagnosis and the prescriber’s reason for overriding the dosage guidelines.
  • Ensure your employees properly document when a beneficiary receives his or her prescription. This is one of the rules that exists to ensure the chain of possession is accurate. When you fill a prescription for someone, you must document that they received their prescription. Maintaining an accurate signature log can help you avoid accusations of fraud.

An Illinois Medicare Pharmacy Audit Defense Lawyer Can Help

Before you are subject to a field audit, CMS will notify you of the date, giving you time to prepare and ensure things are in good working order. A CMS audit can be extremely important -- consequences of a negative audit can range from a simple warning or monetary fine to forfeited CMS reimbursements. At The Law Offices of Joseph J. Bogdan, Inc., we can help you prepare for an upcoming CMS audit or we can help you challenge the results of an already completed audit. Get in touch with our knowledgeable Illinois Medicare pharmacy audit defense attorneys today to begin talking about your case. Call our office at 630-310-1267 to schedule a free consultation.

 

Source:

https://www.cms.gov/Medicare-Medicaid-Coordination/Fraud-Prevention/Medicaid-Integrity-Education/Downloads/pharmacy-selfaudit-booklet4-billing-practice.pdf

 

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