Is Your Pharmacy Ready for an Unannounced Audit?

From PAAS National LLC, released July 12, 2022: Pharmacies are often startled with the limited amount of time a PBM offers prior to an onsite audit. However, PBM auditors, DEA agents, FDA inspectors and state Board of Pharmacy inspectors can also make unannounced visits.

Ensuring your staff members are prepared in case of an unannounced visit is essential. Because these visits occur without warning, the Pharmacist-in-Charge (PIC) and/or owner may not be working or available to assist. Keeping information in a central location and advising staff on how to handle these intimidating visits will make the process go much smoother.
PAAS National® has created a document to help pharmacies prepare for PBM visits. Located on the PAAS Member Portal, under the Tools & Aids Section, PAAS Audit Assistance members can find the Onsite Credentialing Guidelines. This tool provides a list of frequently asked questions from auditors. The guide also includes references to the Policy and Procedure Manual for PAAS National® Fraud, Waste & Abuse and HIPAA Compliance¹ members.

PAAS Tips:

• Anyone requesting access to PHI (or your professional service area) should be identified with a company-issued picture ID and other validating information
  • Follow your pharmacy’s HIPAA policy for visitors. PAAS FWA/HIPAA members can document information on their Visitor’s Log located in their Policy and Procedure Manual
• Check PAAS’ newest guide How to Be Prepared for An Onsite Audit ² located on the PAAS Member Portal in the Tools & Aids Section
• Make sure all staff are:
  • Up to date on FWA and HIPAA compliance training
  • OIG and GSA exclusion checked; required monthly, PAAS performs these checks daily for our FWA/HIPAA members and records are accessible on the PAAS Member Portal
• Review and update your FWA/HIPAA Compliance Manual and the Onsite Credentialing Guidelines with your Compliance Officer and/or PIC
• Keep copies of all documents requested by auditor or inspector
• Keep copies of any documents you are requested to sign
• Contact PAAS at info@paasnational.com or (608) 873-1342 once your PBM visit is over, as we can track this information to better serve all members based on your experience

PAAS National® is committed to serving community pharmacies and helping keep hard-earned money where it belongs. Interested in a customized FWA/HIPAA Compliance Policy and Procedure program? Contact PAAS National® to get started today! info@paasnational.com or (608) 873-1342

By Trenton Thiede, PharmD, MBA, President at PAAS National®, expert third party audit assistance and FWA/HIPAA compliance
©2022 PAAS National® LLC All Rights Reserved

References:

• ¹ https://paasnational.com/fwac-hipaa/
• ² https://portal.paasnational.com/Paas/Resource/Tools