10 minute read
Best Practices for Vaccine Documentation
By Trenton Thiede, PharmD, MBA, President at PAAS National®, expert third party audit assistance and FWA/HIPAA compliance.
Without question, vaccine claims are on the rise! Consequently, PAAS National® analysts have recently seen an increased number of PBM audits for these claims. Consider a few best practices to reduce your risk of audit recoupments:
Billing
Quantity - Submit the correct NCPDP billing unit of each (EA) or milliliter (mL) based on vaccine product Day Supply - NCPDP recommends that all vaccine claims be submitted as a 1-day supply
Origin Code
Submit the origin code in accordance with how you received the prescription • 1 – written, prescription obtained via paper. • 2 – telephone, prescription obtained via oral instructions or interactive voice response using a phone. • 3 – electronic, prescription obtained via SCRIPT or HL7 Standard transactions, or electronically within closed systems. • 4 – facsimile, prescription obtained via transmission use a fax machine. • 5 – pharmacy, this value is used to cover any situation where a new Rx number needs to be created from an existing valid prescription such as traditional transfers, intrachain transfers, file buys, software upgrades/migrations, and any reason necessary to “give it a new number. This value is also the appropriate value for “Pharmacy dispensing” when applicable such as BTC (behind the counter),
Plan B, established protocols, pharmacists’ authority to prescribe, etc. Note that codes 1-4 represent patient-specific prescriptions while code 5 covers various other situations
Prescriber ID
• Submit the NPI of the prescriber • This would be the prescriber of a patient-specific prescription or standing protocol • This would be the pharmacist Type 1 NPI (individual) as per state law where pharmacists have prescribing authority or when ordered under PREP Act declaration during COVID-19 pandemic
Documentation
Item
Authority to Administer • Prescription • Standing Protocol • Collaborative Practice
Agreement (CPA) • PREP Act Declaration
Screening Checklist
Vaccine Administration Record (VAR)
VIS or EUA Fact Sheet
Comments
• You may have a patient-specific prescription with all elements required by state law • You may have a standing protocol or collaborative practice agreement • For situations where you are administering pursuant to a protocol, CPA or PREP Act declaration, PAAS recommends creating a “placeholder prescription” with all normal prescription elements for your files Not requested by PBMs, however should retain for your records
Must document every administration (required by law) Include at least the following: 1. Date of administration 2. Vaccine manufacturer 3. Vaccine lot number and expiration date 4. Site of injection 5. Name and title of the person who administered the vaccine 6. Vaccine information statement (VIS) or EUA Fact Sheet • Date printed on the VIS • Date the VIS was given to the patient or parent/ guardian
Most current version must be provided prior to each administration (required by law)
Requested in audits
Yes
No
Yes
No
PAAS Tips:
• Common errors found during audits are wrong quantity billed and missing VAR documentation • See CDC website1 or immunize.org2 for sample forms and additional resources
PAAS National® is committed to serving community pharmacies and helping keep hard-earned money where it belongs. Contact us today at (608) 873-1342 or info@paasnational.com to see why membership might be right for you. ©2022 PAAS National® LLC All Rights Reserved
REFERENCES
1. https://www.cdc.gov/vaccines/hcp/admin/document-vaccines.html 2. http://immunize.org/
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Employed Pharmacists Hospital Pharmacists Community Pharmacists Clinical Pharmacists Long-Term Care Pharmacists Nuclear Pharmacists Consultant Pharmacists Self-Employed Pharmacists Volunteer Pharmacists Retired Pharmacists Pharmacy Instructors Pharmacy Students What if you have a second job, volunteer, or give advice to a friend or neighbor?
LIMITS OF LIABILITY AND WHAT WE COVER Coverage is available on a Claims-made or Occurrence basis with limits of $1 million
for each claim or occurrence and $3 million aggregate (higher limits may be available).
• Coverage Options: » Exclude Sterile Compounding » Include Sterile Compounding » Advanced Pharmacist License • Immunizations and Other Drug Administration • COVID-19 Testing and Immunizations • Drug Regimen Reviews • Medication Therapy Management • Drug or Drug-Related Research • Medication Consultation • Drug and Device Storage • Participation in Drug and Device Selection • Point-of-Care Testing
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It’s your career.
You can’t afford to be wrong. Apply at www.phmic.com/state-association
Who We Cover
Employed Pharmacists Hospital Pharmacists Community Pharmacists Are You Covered? Clinical Pharmacists Long-Term Care Pharmacists Nuclear Pharmacists Consultant Pharmacists Self-Employed Pharmacists Volunteer Pharmacists What if you were Retired Pharmacists named individually Pharmacy Instructors in a lawsuit? Pharmacy Students What if you have a second job, volunteer, or give advice to a friend or neighbor?
LIMITS OF LIABILITY AND WHAT WE COVER Coverage is available on a Claims-made or Occurrence basis with limits of $1 million
for each claim or occurrence and $3 million aggregate (higher limits may be available).
• Coverage Options: » Exclude Sterile Compounding » Include Sterile Compounding » Advanced Pharmacist License • Immunizations and Other Drug Administration • COVID-19 Testing and Immunizations • Drug Regimen Reviews • Medication Therapy Management • Drug or Drug-Related Research • Medication Consultation • Drug and Device Storage • Participation in Drug and Device Selection • Point-of-Care Testing
Pharmacists License Defense - $250,000 limit Board of Pharmacy Imposed Costs* - $2,500 limit HIPAA Claim Defense - $50,000 limit Assault - $25,000 limit Sexual and Physical Abuse Liability - $50,000 limit (higher limits may be available) *Costs do not include fines or penalties. Coverage may not be available in all states and territories. See policy for full description of coverages. Apply at www.phmic.com/state-association
What if your current employer does not have the proper coverage in place to protect you?
Who We Cover Employed Pharmacists Hospital Pharmacists Are You Covered? Community Pharmacists Clinical Pharmacists Long-Term Care Pharmacists Nuclear Pharmacists Consultant Pharmacists Self-Employed Pharmacists Volunteer Pharmacists What if you were Retired Pharmacists named individually Pharmacy Instructors Pharmacy Students in a lawsuit? What if you have a second job, volunteer, or give advice to a friend or neighbor?
LIMITS OF LIABILITY AND WHAT WE COVER Coverage is available on a Claims-made or Occurrence basis with limits of $1 million
for each claim or occurrence and $3 million aggregate (higher limits may be available).
• Coverage Options: » Exclude Sterile Compounding » Include Sterile Compounding » Advanced Pharmacist License • Immunizations and Other Drug Administration • COVID-19 Testing and Immunizations • Drug Regimen Reviews • Medication Therapy Management • Drug or Drug-Related Research • Medication Consultation • Drug and Device Storage • Participation in Drug and Device Selection • Point-of-Care Testing
Pharmacists License Defense - $250,000 limit Board of Pharmacy Imposed Costs* - $2,500 limit HIPAA Claim Defense - $50,000 limit Assault - $25,000 limit Sexual and Physical Abuse Liability - $50,000 limit (higher limits may be available) *Costs do not include fines or penalties. Coverage may not be available in all states and territories. See policy for full description of coverages. Apply at www.phmic.com/state-association Pharmacists Mutual Insurance Company 808 Highway 18 W | PO Box 370 | Algona, Iowa 50511 P. 800.247.5930 | F. 515.295.9306 | info@phmic.com
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What if your current employer does not have the proper coverage in place to protect you? What if you have a second job, volunteer, or give advice to a friend or neighbor?
LIMITS OF LIABILITY AND WHAT WE COVER Coverage is available on a Claims-made or Occurrence basis with limits of $1 million
for each claim or occurrence and $3 million aggregate (higher limits may be available).
• Coverage Options: » Exclude Sterile Compounding » Include Sterile Compounding » Advanced Pharmacist License • Immunizations and Other Drug Administration • COVID-19 Testing and Immunizations • Drug Regimen Reviews • Medication Therapy Management • Drug or Drug-Related Research • Medication Consultation • Drug and Device Storage • Participation in Drug and Device Selection • Point-of-Care Testing
Pharmacists License Defense - $250,000 limit Board of Pharmacy Imposed Costs* - $2,500 limit HIPAA Claim Defense - $50,000 limit Assault - $25,000 limit Sexual and Physical Abuse Liability - $50,000 limit (higher limits may be available) *Costs do not include fines or penalties. Coverage may not be available in all states and territories. See policy for full description of coverages. Apply at www.phmic.com/state-association Pharmacists Mutual Insurance Company 808 Highway 18 W | PO Box 370 | Algona, Iowa 50511 P. 800.247.5930 | F. 515.295.9306 | info@phmic.com
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