humana pharmacy solutions

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Audit Guide Introduction 1.0 Overview 2.0 Types/Description of Process 2.1 Telephone 2.2 Desktop 2.3 Onsite 3.0 Appeals 4.0 Adjustments 5.0 Documentation Requirements 5.1 For an E-Script 5.2 E-Script Controlled Substances 5.3 Retail 5.4 Long-term-care (LTC) Providers 5.5 Signature Log-Elements 5.6 Retail Pharmacy Providers 5.7 Long-term-care Providers 6.0 General Pharmacy Audit Guidelines 6.1 Quantity/Days Supply 6.2 Insulin 6.3 Dispense As Written (DAW) 6.4 Ophthalmic/Otic Solutions 6.5 Ophthalmic/Otic Suspensions 6.6 Inhalers 6.7 Kits 6.8 Injections 6.9 “As Directed”/ “PRN” 6.10 Compounds 6.11 Reversals 6.12 Origin Code 6.13 Prescriber ID 6.14 Changes to Prescription 6.15 Package Sizes 6.16 Evaluation and Mitigation Strategy (REMS) Programs 6.17 Network Selection 7.0 Discrepancy List 8.0 Appendix: 8.1 Pharmacy Audit Appeal Form 8.2 Humana LTC Pharmacy Documentation Guidelines 8.3 FAQ Document Humana Pharmacy Solutions

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Page 1: Humana Pharmacy Solutions

Audit Guide

Introduction

1.0 Overview

2.0 Types/Description of Process

2.1 Telephone

2.2 Desktop

2.3 Onsite

3.0 Appeals

4.0 Adjustments

5.0 Documentation Requirements

5.1 For an E-Script

5.2 E-Script Controlled Substances

5.3 Retail

5.4 Long-term-care (LTC) Providers

5.5 Signature Log-Elements

5.6 Retail Pharmacy Providers

5.7 Long-term-care Providers

6.0 General Pharmacy Audit Guidelines

6.1 Quantity/Days Supply

6.2 Insulin

6.3 Dispense As Written (DAW)

6.4 Ophthalmic/Otic Solutions

6.5 Ophthalmic/Otic Suspensions

6.6 Inhalers

6.7 Kits

6.8 Injections

6.9 “As Directed”/ “PRN”

6.10 Compounds

6.11 Reversals

6.12 Origin Code

6.13 Prescriber ID

6.14 Changes to Prescription

6.15 Package Sizes

6.16 Evaluation and Mitigation Strategy (REMS) Programs

6.17 Network Selection

7.0 Discrepancy List

8.0 Appendix:

8.1 Pharmacy Audit Appeal Form

8.2 Humana LTC Pharmacy Documentation Guidelines

8.3 FAQ Document

Humana Pharmacy Solutions

Page 2: Humana Pharmacy Solutions

Introduction

Humana Pharmacy Solutions (Humana) values the services offered to Humana members by our network

of pharmacy providers. This Humana Audit Guide is provided to explain Humana‟s Pharmacy Audit

Program. It is our goal for Humana network pharmacies to understand the pharmacy audit process. In

addition, our network pharmacies are prepared to respond appropriately and to cooperate with a

Humana-initiated audit of pharmacy claims.

Humana maintains a pharmacy audit program i.) to help ensure validity and accuracy of pharmacy

claims for our clients (including the Centers for Medicare & Medicaid Services (CMS)), ii.) to help

ensure compliance with the Provider Agreement between Humana and our network pharmacies, and iii.)

to provide education to our network pharmacies regarding proper submission and documentation of

pharmacy claims.

According to the Pharmacy Provider Agreement between Humana and our network pharmacies,

Humana, any third-party auditor designated by Humana, or any government agency allowed by law, are

permitted to conduct audits of any and all books, records and prescription files related to services

rendered to members.

1. Overview

Humana (or its designee) conducts telephone, desktop and onsite audits. The results of these audits are

communicated verbally (in the case of a successfully resolved telephone audit), via mail or via electronic

mail (e-mail). Pharmacies have an opportunity, when applicable, to submit additional documentation or

“post audit” documentation to Humana for additional review. A pharmacy that disagrees with the audit

findings may dispute Humana‟s determination through the submission of the “Pharmacy Audit Appeal

Form,” which will be reviewed by the Pharmacy Audit Appeal Committee. Once appeals have been

heard and a determination has been reached by the Pharmacy Audit Appeal Committee, discrepant

claims will be addressed through the adjustment process.

The Humana pharmacy claim adjustment process addresses discrepant claims through one of the

following methods:

Correct the discrepant claim information, reflecting deduction or addition of funds

from/to the initial payment (partial recovery)

Reversal of a claim (full recovery)

Line item adjustment of a claim (reduction in payment on the pharmacy remittance)

Deductions will be made against future claim submissions and will be recorded on the pharmacy‟s

remittance statement (or 835) after all appeals on the audit findings have occurred.

Audit findings may result in a Corrective Action Plan (CAP). Failure to comply with a CAP may result

in additional audits or additional corrective actions that may include penalties up to and including

termination from Humana‟s pharmacy network.

Failure or refusal to comply with an audit request may result in a full recovery of the total amount paid

to the pharmacy for the claims involved in the audit review, including all amounts or fees paid to the

Page 3: Humana Pharmacy Solutions

pharmacy by Humana and/or its member(s). Refusal or denial to comply with any audit type (as

described below in Section 2) may result in corrective action up to and including termination of the

pharmacy‟s Provider Agreement with Humana.

In General, the Audit Process is:

Humana

Pharmacy notified

of scheduled audit

Humana

Appeal

documentation

reviewed and audit

results finalized

Humana

Review post audit

documentation and

notify pharmacy of

final results

Humana

Notifies pharmacy

of initial audit

results

Humana

Audit reviews

documentation

Pharmacy

Submits

supporting

documentation

Pharmacy

Appeal window to

submit appeal

form

Pharmacy

Post audit window

to submit rebuttal

documentation

Humana

Claims adjustment

process

Audit complete

2. Audit Types/Description of Process

Humana currently utilizes the following types of pharmacy audit:

2.1 Telephone

In some cases, the pharmacy may be contacted via phone to verify claim(s) submission and request the

pharmacy to correct claim billing, if necessary. This type of audit will only be done on a small number

of claims; any large group of claims will be reviewed through desktop or onsite processes. Failure to

comply with a telephone audit will result in either a desktop or an onsite audit.

2.2 Desktop

Claims selected for desktop audit are grouped together and audited concurrently. The pharmacy will

receive, via established communication method (most often letter), a communication requesting claim(s)

documentation from the pharmacy that will include a specific deadline (typically 30 calendar days), the

claim(s) being audited, required documentation, and auditor contact information. The pharmacy must

submit requested documentation for all indicated claims back to Humana to substantiate and validate

claims previously received. Failure to respond to an audit by the initial due date (unless an extension is

granted prior to the due date) will result in assessment of a penalty according to the following chart:

If documentation is received: Penalty assessed will be:

Prior to the audit deadline None

After the audit deadline but before the

post audit deadline

25 percent of the total value of the audited

claims

Page 4: Humana Pharmacy Solutions

After the post audit deadline 100 percent of the total value of the

audited claims

The pharmacy may submit documentation to Humana via mail or e-mail. Humana will review

documentation submitted by the pharmacy to validate accuracy of the documentation for the claim

previously submitted, and for compliance with all laws, rules, regulations, Humana benefit limits or

other requirements as outlined in the Pharmacy Provider Manual and Pharmacy Provider Agreement.

Upon review of all documentation, an initial audit result letter will be sent to the pharmacy.

The pharmacy will be allowed approximately 30 calendar days from the date of the initial audit result

letter to supply additional documentation to mitigate discrepant claims (see Humana Discrepancy List

for acceptable documentation, in Appendix 6.1). Humana will review any additional documentation

received by the deadline and determine if any previous discrepancies can be removed. Upon review of

any and all documentation received prior to the deadline, a final audit result letter will be sent to the

pharmacy.

The pharmacy will be allowed approximately 15 calendar days from the date of the final audit result

letter (specified in the final audit result letter) to further dispute by submitting an appeal. All appeals

must be properly submitted on an appeal form, as outlined in section 3.0.

2.3 Onsite

A pharmacy selected for an onsite audit will receive a notification letter via mail, which specifies the

date of the audit, date range of claims being audited and auditor contact information. The auditor will

follow up with the pharmacy approximately seven calendar days prior to the audit to supply additional

information for the pharmacy to prepare for the audit and to answer any questions. Failure to comply

with an onsite audit may result in a penalty equal to the total value of the audited claims, as well as a

corrective action up to and including termination from Humana‟s pharmacy network.

An onsite audit will be conducted at the pharmacy‟s physical location. The auditor will review

documentation including, but not limited to, hard copy prescription documentation, signature logs,

documentation logs (if any) and compliance with the Pharmacy Provider Agreement. Humana requires

the auditor be provided a clean work space, away from the dispensing area (as to not disrupt pharmacy

practice), and assistance in locating requested audit documentation. All documentation must be pulled

within eye sight of the auditor, if possible, or the auditor reserves the right not to accept the

documentation. An onsite audit will generally involve more claims than a telephone or desktop audit.

The onsite auditor will also review pharmacy procedures, compliance with specific sections of the

Provider Agreement, and any applicable rules, laws and regulations. Upon review of all documentation,

an initial audit result letter will be sent to the pharmacy, typically within seven to 10 business days of the

onsite audit.

The pharmacy will be allowed approximately 30 calendar days from the date of the initial audit result

letter to supply allowable additional documentation to mitigate discrepant claims (see Humana

Discrepancy List for acceptable documentation, located in Appendix 6.1). The auditor will review

additional documentation received by the deadline and determine if any previous discrepancies can be

Page 5: Humana Pharmacy Solutions

removed. Upon review of any and all documentation received prior to the deadline, a final audit result

letter will be sent to the pharmacy.

The pharmacy will be allowed approximately 15 days from the date of the final audit result letter

(specified in the final audit result letter) to further dispute by submitting an appeal. All appeals must be

properly submitted on an appeal form, as outlined in section 3.0.

3.0 Appeals

All pharmacies are provided an opportunity to respond to audit findings by filing a written appeal on the

“Pharmacy Audit Appeal Form” (see Pharmacy Audit Appeal Form, in Appendix 8.1) within 15 days

from the date of the final audit result letter. The intent of the appeal is to allow pharmacies the

opportunity to provide a written explanation describing why the pharmacy disagrees with the audit

findings for each claim deemed discrepant. It is not expected that pharmacies will produce additional

prescription documentation during an appeal, as it is expected that the pharmacy would have submitted

all applicable documentation prior to an appeal. Appeals should be submitted via certified United States

Postal Service®, FedEx

®, UPS

® or other certified carrier. The Humana Pharmacy Appeal Committee

will not, as a matter of policy, review appeals or disputes not submitted on the Humana Pharmacy Audit

Appeal Form. Upon review of an appeal, an appeal results letter will be sent to the pharmacy, detailing

the decision of the Humana Pharmacy Appeal Committee.

4.0 Adjustment

Any calculations represented on any initial or final audit reports are estimated or proposed recoveries.

Actual recovery amounts are not known until the claim adjustments occur and are communicated

through the pharmacy‟s remittance advice statement.

Humana will offset amounts due to Humana due to audits from subsequent pharmacy payments until the

audit recoveries have been collected in full. In the event Humana is unable to offset from future

payments, the pharmacy must pay Humana the amount owed within 30 calendar days of written notice

from Humana.

5.0 Documentation Requirements

In general, for a hard copy prescription or electronic prescription, the front and back of the hard copy or

electronic prescription documentation must be submitted. The following are elements of the prescription

that must be included on the documentation (unless contradicted by state law) for the documentation to

be considered acceptable:

Name of the patient

Date of prescription issuance

Name, strength and dosage form (if applicable) of the drug prescribed

Directions for use (or the maximum daily dosage allowed by the prescriber)

Quantity prescribed

Number of refills (or a clear start and stop date or for cycle fills a continue until told

to discontinue date)

Page 6: Humana Pharmacy Solutions

National Provider Identifier (NPI) of the prescriber (or at minimum the name of the

prescriber for nonscheduled medications)

Prescriber‟s Drug Enforcement Agency (DEA) registration number (for scheduled

medications)

Prescriber‟s signature (or in the case of a phone-in prescription order the full name of

the individual from whom the pharmacist received the prescription order)

The unique prescription identifier (prescription number)

5.1 Documentation Requirements for an Electronic Prescription

According to the Pharmacy Provider Agreement, pharmacies must be able to accept electronically

submitted prescriptions from prescribers in National Council for Prescription Drug Programs (NCPDP)

Version 8.1 (Prescriber/Pharmacist Interface SCRIPT Standard, Implementation Guide) or most current

NCPDP format. Pharmacies are required to populate NCPDP field 419-DJ with the prescription origin

code of three for all prescriptions submitted to a provider using an ePrescribing method for claims

submitted to Humana‟s claims processor/administrator.

5.2 Documentation Requirements Electronic Prescriptions for Scheduled Medications

Pharmacy systems must comply with Drug Enforcement Agency (DEA) guidance related to

requirements for electronic prescribing of controlled substances. Pharmacy systems that accept

electronically prescribed prescriptions for scheduled medications must retain digital signatures received.

Pharmacies must also validate the DEA registration of a prescriber from whom an electronic

prescription has been received when there is some reason to suspect a lack of validity.

5.3 Documentation Requirements for Retail Pharmacy Providers

There are no additional requirements related to hard copy prescription documentation, unless otherwise

required by law.

5.4 Documentation Requirements for Long-term-care Providers

Humana recognizes the elements of a prescription may not be found on one hard copy prescription, but

requires a combination of the “Chart Order” and the “Prescription Drug Order” to constitute a full hard

copy prescription. Please see Appendix 8.2 for long-term-care guidelines.

5.5 Signature Log Elements

Humana requires, at minimum, the following data elements on all signature logs:

Page 7: Humana Pharmacy Solutions

Full Patient Name

Date of Fill

Rx Number

Signature of the Member (or legal representative)

Date of Pick Up or Delivery

5.6 Signature Log Elements for Retail Pharmacy Providers

All of the elements listed above must be present on a signature log, unless required by law.

5.7 Signature Log Elements for Long-term-care Providers

Humana recognizes that, generally, long-term-care pharmacies do not collect signature logs as is the

standard for retail pharmacy providers. If a signature log is provided by a long-term-care pharmacy and

meets the requirements of a retail pharmacy provider, Humana will accept it as a signature log for a

long-term-care provider. However, if a signature log is not available, Humana requires a delivery

manifest or other documentation that clearly displays the member received the medication. Please see

Appendix 8.2 for long-term-care guidelines.

5.8 Additional Documentation

Humana has the right to request additional documentation for auditing purposes, which includes, but is

not limited to, the following:

Purchase Invoices and Reports

Credentialing Documentation

Contract Compliance Documentation

Compliance with Medicare Rules and Regulations

Training Documentation

Employee Documentation

6.0 General Pharmacy Audit Guidelines

6.1 Quantity/Days Supply The quantity prescribed by the physician should be dispensed and submitted to Humana in

conjunction with the correct days supply. If Humana rejects the claim, due to quantity or days

supply limits, the claim should be readjudicated with a quantity and days supply consistent with the

directions for use and the plan‟s specific limitations. For eye drops, inhalers and topical agents, if

the prescription is written for a quantity of one, the pharmacy should dispense the smallest

commercially available product. If a larger package size is dispensed, an appropriate reason should

be documented either on the hard copy prescription or within another readily retrievable system and

should be provided during an audit.

Page 8: Humana Pharmacy Solutions

6.2 Insulin Claims should be submitted for the correct quantity and days supply based upon the number of units

per day. As it is typical for insulin doses to vary, a maximum daily dose should be used to calculate

the quantity and days supply. The maximum daily dose should always be documented on the hard

copy prescription and should be provided during an audit.

6.3 Dispense As Written (DAW)

Humana recognizes the NCPDP codes for dispense as written situations. For any prescription submitted

with a DAW code other than zero, the reason for the selected code must be documented and must be in

compliance with all applicable laws, rules and regulations.

6.4 Ophthalmic/Otic Solutions Unless otherwise indicated by the manufacturer, Humana calculates solutions as having 20 drops

per milliliter (mL). All claims should be submitted based upon the 20 drops per mL guideline and

adjusted to the proper quantity and days supply accordingly.

6.5 Ophthalmic/Otic Suspensions Unless otherwise indicated by the manufacturer, Humana calculates suspensions as having 15 drops per

milliliter (mL). All claims should be submitted based upon the 15 drops per mL guideline and adjusted

to the proper quantity and days supply accordingly.

6.6 Inhalers In most cases, inhalers should be submitted according to the metric decimal quantity as indicated by the

manufacturer and not by the number of inhalations for the given inhaler.

6.7 Kits In most cases, kits should be billed by the number of kit(s) dispensed at the time of fill, not the

number of units found within the kit. If the number of kit(s) is not applicable, reference the First

Data Bank (http://www.firstdatabank.com).

6.8 Injections

In general, injections should be billed by the number of mL being dispensed, not the number of

injections or bottles dispensed. If the number of mL is not applicable, reference the First Data Bank

(http://www.firstdatabank.com).

Page 9: Humana Pharmacy Solutions

6.9 “As Directed”/ “PRN”

With the exception of dosage packs, Humana prohibits the use of “As Directed.” For drugs that may

fluctuate dosage, a maximum or “up to” daily dose should be used to calculate the appropriate days

supply and documented on the hard copy prescription. For topical agents, the affected area should be

documented on the hard copy prescription or another readily retrievable system, unless dispensing the

smallest commercially available package.

6.10 Compounds The cost of the compound should not exceed the contract rate of the covered ingredients used. Upon

audit, Humana will require a compound worksheet be submitted for each compound, which

includes the NDC, quantity and cost of each ingredient.

6.11 Reversals Humana requires any claims not picked up within 15 business days to be reversed.

6.12 Origin Code For a new prescription, a valid Prescription Origin Code (POC) must be submitted beginning

January 1, 2010. Humana requires this field to be populated correctly for all claims, Medicare and

commercial. POC is to be populated with the approved valid values below:

1 = Written

2 = Telephone

3 = Electronic

4 = Facsimile

6.13 Prescriber ID Humana requires the correct National Provider Identifier (NPI) be submitted for each claim. When

an NPI is not available or cannot be obtained, the appropriate Drug Enforcement Agency (DEA)

registration number may be used. Submission of an incorrect, invalid or “dummy” prescriber

identifier will result in a claim being considered discrepant.

6.14 Changes to Prescriptions Any change in an element of a prescription, as defined in section 5.0 (Documentation

Requirements), must be documented and submitted along with all other documentation related to

the hard copy prescription.

Page 10: Humana Pharmacy Solutions

6.15 Package Sizes The package size dispensed must be the proper package size based upon the directions of the

prescription. If the proper package size is not in stock, Humana expects (unless in an emergency)

either the smaller package size will be dispensed or the proper package size will be ordered for

dispensing within 24 hours.

6.16 Risk Evaluation and Mitigation Strategy (REMS) Programs

Medications with special and specific Food and Drug Administration (FDA) guidelines must be

dispensed in accordance with the guidelines.

6.17 Network Selection All claims must be submitted to the appropriate network and reimbursed based upon the rate for the

network. To ensure the correct network is selected, ensure the days supply is correctly calculated

and the patient location code and level of service fields are entered appropriately.

7.0 Discrepancy List

The Discrepancy Code List defines each type of potential discrepancy identified during an audit. In

addition, this list should be used to respond to the audit findings. Finally, it provides justification for the

type of charge back occurring upon finalization of the audit.

Humana requires the following elements to consider a prescriber statement valid for post-audit

documentation:

The address and telephone number of the prescriber should be printed on the

prescriber‟s own letterhead

Member name, medication(s), date(s) of service, strength, directions, quantity ordered

and refills (if applicable) should be included within the document

The original method and date of the prescription should be included within the

document

The document should include the prescriber‟s signature

Note: “Call in” or “Phone in” prescriptions are not acceptable during the post audit phase.

Humana requires the following elements to consider a member statement valid for post-audit

documentation:

Member address and telephone number

Medication(s), Rx number(s) and date(s) of service

Page 11: Humana Pharmacy Solutions

Member signature

BMN – Dispense as Written

Definition:

Brand medication billed, but member or prescriber‟s “brand-only” order is not

documented. Prescriber must specify "Dispense as Written" on hard copy or

pharmacy must document prescriber request or, when required by state

regulations, member request for brand name dispensing.

Acceptable Post

Audit

Documentation:

DAW 1 – Prescriber Statement, which validates that the substitution of

generic product was authorized.

DAW 2 – Member Statement, which validates that the substitution of

generic product was authorized.

DAW 7 – Legal reference, which mandates that a specific product be

dispensed by brand name only.

Discrepancy

Result:

Partial charge back due to pharmacy submitting incorrect DAW code. Claim will

be corrected in the amount of the difference between the brand and generic

contracted rate.

CPDF – Compound Incorrectly Billed

Definition: A compounded prescription is incorrectly billed resulting in an overpayment.

Acceptable Post

Audit

Documentation:

Compound worksheet with ingredients listed National Drug Code (NDC) and

Quantity.

Discrepancy

Result:

Full charge back due to compound being billed with noncovered Part D drugs, an

incorrect compound indicator or other indicators that lead to inappropriate

payment.

CPDP – Compound Incorrectly Billed

Definition: A compounded prescription is incorrectly billed resulting in an overpayment.

Acceptable Post

Audit

Documentation:

Compound worksheet with ingredients listed (NDC and Quantity).

Discrepancy

Result:

Repriced with compound worksheet. The overpriced amount will be recovered

based upon the pricing available in the compound worksheet.

CPDW – Compound Worksheet Required

Definition: Prescription is submitted using an inappropriate compound indicator or incorrect

NDC #.

Acceptable Post

Audit

Documentation:

Compound worksheet required.

Discrepancy

Result:

Full charge back due to missing compound worksheet to validate the claim.

Page 12: Humana Pharmacy Solutions

DDB – Different Drug Billed

Definition:

Pharmacy billed for a different medication than the one ordered by the prescriber

with no documentation on prescription or member profile.

Acceptable Post

Audit

Documentation:

For therapeutic exchange, prescriber statement will be accepted in post

audit to verify change was authorized in prescribed product.

All other discrepancies not due to therapeutic exchange, no post audit

documentation will be accepted.

Discrepancy

Result:

Full charge back due to pharmacy submitting claim for different product than

prescribed. Documentation should be available at the time of audit.

DEA – No DEA

Definition: The hard copy prescription does not contain a DEA number (CII-CV drugs only).

Acceptable Post

Audit

Documentation:

No post-audit documentation will be accepted.

Discrepancy

Result:

Full charge back because this element is required by law for a controlled substance

prescription to be valid. Post-audit documentation will not be accepted because

according to federal regulations, the prescriber DEA should be on the prescription

hard copy prior to dispensing. If a controlled substance prescription does not

contain the prescriber's DEA, the prescription should not be filled until the

prescriber's DEA can be obtained and documented.

DID – Wrong Prescriber

Definition: Incorrect prescriber billed or inappropriate use of prescriber ID.

Acceptable Post

Audit

Documentation:

Prescriber statement from a nonsanctioned prescriber that shows the

prescriber billed is a member of the same practice as the correct prescriber

or proof that a reasonable effort was made to bill the correct prescriber ID.

CII-CV, no post-audit documentation will be accepted.

Discrepancy

Result:

Full charge back due to pharmacy submitting claim with an incorrect prescriber ID

or with a sanctioned prescriber ID. A prescriber statement from a nonsanctioned

prescriber will be accepted as post-audit documentation to verify the submitted

prescriber is from the same practice as the correct prescriber. No post-audit

documentation will be allowed for controlled substance prescriptions.

Page 13: Humana Pharmacy Solutions

DN-1 – Wrong Member Billed

Definition:

The member identified on a hard-copy prescription is not the member identified on

the paid claim.

Acceptable Post

Audit

Documentation:

Member statement or member identification

Discrepancy

Result:

Full charge back due to claim billed to wrong member. A member statement will

be accepted during post audit to clarify the member‟s identification.

DUP – Duplicate Claim

Definition: Multiple claims for the same prescription fill were paid. A duplicate claim is

defined as the same member, product, dosage and close approximate fill dates.

Acceptable Post

Audit

Documentation:

No post-audit documentation will be accepted.

Discrepancy

Result:

Full charge back due to duplicate claim. Humana's expectation is that pharmacies

will obtain appropriate authorization to fill scripts early rather than circumventing

system edits. No post-audit documentation will be accepted because this situation

could lead to a potential patient safety risk.

EQB – Exceeds QTY Limits/Overfilled QTY

Definition:

Quantity billed exceeds the quantity authorized by the prescriber or plan. The

pharmacy submitted a quantity greater than the quantity prescribed or a quantity

that would last greater than the days supply limit of the plan.

Acceptable Post

Audit

Documentation:

No post-audit documentation will be accepted.

Discrepancy

Result:

Partial charge back will reflect the difference between the original paid amount

and the corrected paid amount. No post-audit documentation will be allowed for

excessive quantity.

EXP – Exceeds Time Limit

Definition:

The prescription is filled or refilled for a time period longer than allowed by the

plan or applicable law.

Acceptable Post

Audit

Documentation:

An updated copy of the state code or federal regulation defining the valid length of

time that prescriptions of the control level in question may be filled.

Discrepancy

Result:

Full charge back of discrepant claim submissions due to the prescription expiring

prior to being dispensed. Updated legal information allowed for post-audit

documentation, if pharmacy can provide legal reference that can be validated as

more current or different from what was cited in audit.

Page 14: Humana Pharmacy Solutions

FBW – Filled before Written

Definition: Prescription was filled before date written.

Acceptable Post

Audit

Documentation:

Prescriber statement that validates the prescriber indicated the incorrect date.

Discrepancy

Result:

Full charge back due to claim being billed before script was written. Prescriptions

should not be filled before the original date written without authorization from the

prescriber.

FTR – Failure to Respond

Definition: Pharmacy fails to respond to audit.

Acceptable Post

Audit

Documentation:

Tracking evidence indicating that the pharmacy attempted to mail the audit

documentation within the audit window.

Discrepancy

Result:

Full charge back due to pharmacy not responding to desktop audit. Tracking

information showing proof of delivery or attempt to ship package.

ICS – Wrong Pack Size

Definition:

The package size submitted on the claim differs from the package size dispensed

by the pharmacy or if the pharmacy bills multiples of a smaller size NDC when a

stock larger size is available resulting in excess margins.

Acceptable Post

Audit

Documentation:

Documentation from wholesaler that shows supply issues occurred at the time of

fill with the larger package size.

Discrepancy

Result:

Full charge back due to pharmacy submitting claim for different product than

prescribed (acceptable substitution an exception) or claim submitted for incorrect

package size. Prescriber statement allowed for post audit to verify change in

prescribed product or wholesaler documentation verifying that the specific

package size in question was not in stock or unavailable at the time of fill.

IDS – Wrong or Incorrect Day Supply

Definition:

The days supply value submitted by the pharmacy is not consistent with the

quantity and directions.

Acceptable Post

Audit

Documentation:

No post-audit documentation will be accepted.

Discrepancy

Result:

Partial charge back due to pharmacy submitted incorrect day supply calculation

per prescribed directions. No post-audit documentation allowed because submitted

day supply does not match the hard copy's prescribed directions.

Page 15: Humana Pharmacy Solutions

INV – No Date Written

Definition: Hard copy prescription contains no written date, as required by law.

Acceptable Post

Audit

Documentation:

Prescriber statement (CII-CV, no post-audit documentation will be accepted.)

Discrepancy

Result:

Full charge back because this element is required by law for a prescription to be

valid. Prescriber statement will be allowed for post-audit documentation to verify

that submitted information is correct.

INVP – No Doctor Name

Definition:

The hard copy prescription does not identify the Prescriber by signature, as

required by law.

Acceptable Post

Audit

Documentation:

Prescriber statement (CII-CV, no post-audit documentation will be accepted.)

Discrepancy

Result:

Full charge back because this element is required by law for a prescription to be

valid. Prescriber statement will be allowed for post-audit documentation to verify

that submitted information is correct.

INVD – No Drug Name

Definition:

The hard-copy prescription does not contain the name of the drug to be dispensed,

as required by law.

Acceptable Post

Audit

Documentation:

Prescriber statement (CII-CV, no post-audit documentation will be accepted.)

Discrepancy

Result:

Full charge back because this element is required by law for a prescription to be

valid. Prescriber statement will be allowed for post-audit documentation to verify

that submitted information is correct.

INVN – No Member Name

Definition: The hard-copy prescription contains no member name, as required by law.

Acceptable Post

Audit

Documentation:

Prescriber statement (CII-CV, no post-audit documentation will be accepted.)

Discrepancy

Result:

Full charge back because this element is required by law for a prescription to be

valid. Prescriber statement will be allowed for post-audit documentation to verify

that submitted information is correct.

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INVS – No Strength

Definition:

The hard-copy prescription, for a drug available in more than one strength, fails to

identify the strength to be dispensed, as required by law.

Acceptable Post

Audit

Documentation:

Prescriber statement (CII-CV, no post-audit documentation will be accepted.)

Discrepancy

Result:

Full charge back because this element is required by law for a prescription to be

valid. Prescriber statement will be allowed for post-audit documentation to verify

that submitted information is correct.

IOC – Incorrect Origin Code

Definition: The origin code submitted for the claim differs from the hard-copy prescription.

Acceptable Post

Audit

Documentation:

No post-audit documentation will be accepted.

Discrepancy

Result:

This element is used during a desktop audit to ensure that submitted

documentation is accurate as referenced in Humana's provider contract. CMS has

also provided guidance stressing the accuracy of this field for correct Prescription

Drug Event (PDE) submissions. Full charge back due to pharmacy submitting

claim with an incorrect origin code. Post-audit documentation will not be allowed

because there is no reasonable documentation available to remove the discrepancy

due to the requirement to submit the correct origin code at the time of fill.

LAWF – Law Not Followed

Definition: Prescription not filled in accordance with state/federal law.

Acceptable Post

Audit

Documentation:

An updated copy of the state code or federal regulation with reference code

number.

Discrepancy

Result:

Full charge back due to pharmacy not operating in observance of federal or state

regulations. Updated law information allowed for post-audit documentation if

pharmacy can provide legal reference that can be validated as more current or

different from what was cited in the audit.

LAWP – Law Not Followed

Definition: Prescription not filled in accordance with State/Federal law.

Acceptable Post

Audit

Documentation:

An updated copy of the state code or federal regulation with reference code

number.

Discrepancy

Result:

Partial charge back due to pharmacy not operating in observance of federal or state

regulations. Updated law information allowed for post audit if pharmacy can

provide legal reference that can be validated as more current or different from

what was cited in audit.

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MP-1 – Missing Prescription

Definition: Original hard-copy prescription cannot be found on file during the audit.

Acceptable Post

Audit

Documentation:

Prescriber statement.

Discrepancy

Result:

Full charge back due to pharmacy not providing prescription authorization record.

Prescriber statement allowed for post-audit documentation to verify that

prescription was written by prescriber for specific member and listed date.

MSLD – Not Dispensed

Definition:

Prescription is billed, but not dispensed to member. Drugs are not returned to

stock. Partial fills not picked up and not reversed.

Acceptable Post

Audit

Documentation:

Member statement.

Discrepancy

Result:

Full charge back due to prescription not being picked up or delivered. Member

statement allowed for post-audit documentation to confirm receipt of prescription.

MSL – Signature Not Found

Definition:

The signature documenting receipt of pharmacy services cannot be found in the

signature logs.

Acceptable Post

Audit

Documentation:

Member statement.

Discrepancy

Results

Full charge back due to prescription not being picked up or delivered. Member

statement allowed for post-audit documentation to confirm receipt of prescription.

NORX – No Rx Number

Definition: The hard copy prescription contains no unique prescription identifier number.

Acceptable Post

Audit

Documentation:

A computer generated label/sticker with all defined prescription elements.

Discrepancy

Result:

Full charge back because this element is required by law for a prescription to be

valid. Computer-generated label will be allowed for post-audit documentation to

verify that submitted information is correct.

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NQY – No Quantity

Definition: Prescription quantity is not complete; no quantity on prescription.

Acceptable Post

Audit

Documentation:

Prescriber statement.

Discrepancy

Result:

Full charge back because this element is required by law for a prescription to be

valid. Prescriber statement will be allowed for post-audit documentation to verify

that submitted information is correct.

NSI – No Directions For Use or Use as Directed

Definition: Prescription lacks specific, calculable directions (use as directed or missing

directions).

Acceptable Post

Audit

Documentation:

Prescriber statement (must include exact directions or a maximum daily dose).

Discrepancy

Result:

Full charge back because this element is required by law for a prescription to be

valid. Also required for accurate dosage and day supply calculation. Prescriber

statement will be allowed for post-audit documentation to verify that submitted

information is correct.

OTHF – Miscellaneous Discrepancy

Definition:

„OTHER‟ is assessed when an issue has been cited that is not listed elsewhere on

the discrepancy list. Detailed explanation will be given when this discrepancy is

cited.

Acceptable Post

Audit

Documentation:

Depends upon discrepancy. Detailed explanation will be given when this

discrepancy is cited.

Discrepancy

Result:

Full charge back due to any other reason not listed elsewhere on the Humana

Pharmacy Solutions Audit Discrepancy Code List. This discrepancy will be cited

when circumstance requires claim correction and education to pharmacy. Post-

audit documentation will be allowed or not allowed depending on discrepancy and

circumstance.

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OTHP – Miscellaneous Discrepancy

Definition:

„OTHER‟ is assessed when an issue has been cited that is not listed elsewhere on

the discrepancy list. Detailed explanation will be given when this discrepancy is

cited.

Acceptable Post

Audit

Documentation:

Depends upon discrepancy. Detailed explanation will be given when this

discrepancy is cited.

Discrepancy

Result:

Partial charge back due to any other reason not listed elsewhere on the Humana

Pharmacy Solutions Audit Discrepancy Code List. This discrepancy will be cited

when circumstance requires claim correction and education to pharmacy. Post-

audit documentation will be allowed or not allowed depending on discrepancy and

circumstance.

RXC – Altered Prescription

Definition: Prescription altered without appropriate documentation.

Acceptable Post

Audit

Documentation:

Prescriber statement validating changes were authorized and appropriate.

Discrepancy

Result:

Full charge back due to unauthorized or improperly documented alterations to

prescription hard copy. A prescriber statement will be allowed for post-audit

documentation to confirm or validate that changes were authorized and

appropriate.

RXCQ – Cut Quantity

Definition:

A quantity less than that prescribed is billed and additional refills are dispensed

resulting in undue dispensing fees.

Acceptable Post

Audit

Documentation:

Member statement that indicates a request for change.

Discrepancy

Result:

Partial charge back in the amount of the dispensing fee due to the pharmacy

submitting incorrect quantity by submitting a quantity greater than the face value

of the RX or by cutting the quantity to less than prescribed. No post-audit

documentation will be allowed for excessive quantity. A member statement will be

allowed for post-audit documentation on cut quantity. Member statement will be

used to confirm his/her request to receive less than prescribed.

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UAR – Unauthorized Refill

Definition: Prescription is refilled more times than prescribed.

Acceptable Post

Audit

Documentation:

Prescriber statement validating prescriber's authorizing refills prior to refill being

submitted.

Discrepancy

Result:

Full charge back for any claims submitted for unauthorized refills due to number

of authorized refills exceeded or incorrect calculation of quantity or day supply.

Prolonged duration of therapy could lead to a potential patient safety risk.

Prescriber statement will be allowed for post-audit documentation, validating

prescriber authorized additional refills prior to refill being filled.

UAR2 – Refill Too Soon

Definition:

Prescription is refilled sooner/more frequently than appropriate with respect to

quantity and directions for use.

Acceptable Post

Audit

Documentation:

No post-audit documentation will be accepted.

Discrepancy

Result:

Full charge back due to duplicate claim (same member, product, dosage and close

approximate fill dates) or refill too soon (that misses Refill Too Soon (RTS) logic

due to incorrect submitted day supply). Humana's expectation is that pharmacies

will obtain appropriate authorization to fill scripts early rather than circumventing

system edits. This situation could lead to a potential patient safety risk. Post-audit

documentation will not be allowed because there is no reasonable documentation

available to remove the discrepancy as a previous claim was submitted incorrectly

that allowed this claim to pay.

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8.0 Appendix

8.1 Pharmacy Audit Appeal Form

PHARMACY AUDIT APPEAL FORM

INSTRUCTIONS

Audited pharmacies have the right to appeal the findings of an audit. The intent of the appeal

process is to allow pharmacies the opportunity to provide a written explanation for each

prescription marked discrepant. Pharmacy audit appeals are heard by the Humana Appeal

Committee. The appeal committee conducts its review based on the original audit

documentation submitted and the appeal explanation provided by the pharmacy for the

claim(s) in question. Pharmacies should utilize the Pharmacy Audit Appeal Form to provide

an explanation as to why they disagree with Humana Pharmacy Solutions‟ audit findings for

each prescription deemed discrepant.

In order for an appeal to be reviewed by the Humana Appeal Committee, all of the

information requested in the attached Pharmacy Audit Appeal Form must be provided for

each disputed prescription prior to the appeal deadline. Only claims submitted on a properly

completed Pharmacy Audit Appeal Form will be reviewed by the Humana Appeal Committee.

Appealing pharmacies may only provide information and documentation different from what

was originally submitted for the audit. The pharmacy may include additional sheets or attach a

type written explanation to the Pharmacy Audit Appeal Form, if needed.

If you have any questions about your appeal or the appeal process, please call 502-580-3232

or e-mail [email protected].

Upon Humana Appeal Committee review, you will be notified of the appeal decision.

[Form number must go here]

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PHARMACY AUDIT APPEAL FORM

Pharmacy

Name:_______________________________________________________________

NCPDP/NPI #: _____________________________ Audit Date:

___________________

Pharmacy Contact Name: ______________ Contact Phone Number:

_____________________

Prescription Number:

___________________________________________________________

Date(s) of Service:

_____________________________________________________________

Humana Audit Discrepancy Code: _____________________________________________

Reason for Appeal:

___________________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________

___________________________________

Attachment Included: Yes / No

FOR HUMANA PHARMACY SOLUTIONS INTERNAL USE ONLY

DATE RECEIVED: ____________________________________

APPEAL MEETING DATE: ____________________________________

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8.2 Humana LTC Pharmacy Documentation Guidelines

Source: National Association of Boards of Pharmacy and American Society of Consultant Pharmacist

(NABP/ASCP) Joint Report: Model Rules for Long-term-care (LTC) Pharmacy Practice, which is a

guideline of how NABP and ASCP believe LTC pharmacies should be operating.

LTC pharmacy audits may require auditors to look at multiple pieces of documentation to determine

whether the billed claim is appropriate.

For a hard copy prescription – the following are elements of the prescription that must be included on

the documentation to be considered acceptable: name of the member, date of issuance, name, strength,

and dosage form of the drug prescribed (if applicable), directions for use, quantity prescribed, number of

refills (or a clear start and stop date or for cycle fills a continue until told to discontinue date), DEA or

NPI of the prescriber or name of the prescriber for noncontrolled prescriptions, and the prescriber‟s

signature.

Acceptable Forms of Documentation:

1. Either the combination of the "Prescription Drug Order," AND the "Chart Order" or either of

the above elements found by itself

2. A hard copy prescription from a prescriber as defined by state law

3. A telephone prescription with all appropriate information as defined by state law

4. A properly documented E-script

5. Fax request for refills, as long as it contains all appropriate information (as found on a retail

audit) and is clear it came from and was approved by a prescriber

6. Discharge orders with a clear start and stop date

7. Progress notes – may accept prescriber order written in progress notes if prescriber notes

contain all appropriate prescription elements

8. Any other documentation or combination of documentation that displays all prescription

elements and demonstrates clearly that the documentation originated from a prescriber

The following will NOT be accepted as a hard copy prescription:

1. Medication Administration Records (MARs) or copies of MARs

2. LTC nurse call-in notes for controlled substances

3. Labels, which do not contain required prescription information

4. Progress notes (unless they contain all prescription information)

5. Screen prints (unless for an E-script)

6. Refill sticker alone

For Signature Logs ANY of the following should be accepted:

For signature logs, the following are elements of the log that must be included on the documentation to

be considered acceptable: If a patient picks up the medication at the facility – patient name, RX

number(s), date of service, signature of who received the medication and date received. If delivered to a

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facility – patient name, date of service, RX number(s), date of service, facility delivered, date of delivery

and name of person who received medication.

1. A signature log with all required elements

2. A delivery manifest, with all elements, or a delivery manifest on which the prescriptions

delivered can be traced back to the order number

3. A copy of an MAR, which shows the prescription was administered and the name and

signature of the person who administered the mediation, the date and time the medication

was administered

4. Dated and signed statement from nurse or staff member with appropriate information as

listed above

The following will NOT be accepted for a signature/delivery log:

1. Patient receipt without patient signature

2. Compound worksheet

3. Any documentation that does not clearly display what was delivered, who delivered the

medication, where it was delivered and the date of the delivery.

Cycle Fills:

As per the Humana Pharmacy Provider Manual:

LTC pharmacies that provide medications in a cycle fill type of system may bill through the

point-of-sale system on a cycle basis, as long as the cycle doesn‟t interfere with the normal

day supply and quantity limit (QL) edits. This may be done at the first of the month or at the

end of the month, as long as the time interval in between billing cycles is consistent.

In addition, cycle fills may be utilized for maintenance medications only. For cycle fills, documentation

must clearly state the prescriber intended and authorized for the member to continue the medication.

Documentation Submission:

For chain pharmacies, documentation should be sent per your chain requirements. For independents, all

documentation should be sent to Humana Pharmacy Solutions at the following address:

Attention: Pharmacy Audit – WFP 6W

325 W Main Street

Louisville, KY 40202

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8.3 FAQ Document

Audit Frequently Asked Questions (FAQ)

1. Q: Why is my pharmacy being audited and how can I prevent future audits?

A: All claims are reviewed by multiple audit factors on a daily basis. Claims are selected

randomly for audit through the use of these factors.

2. Q: For a telephone audit, can I correct the claim(s) being audited?

A: Yes. If a telephone audit occurs, pharmacies are encouraged to reverse and correctly

reprocess the discrepant claims at the time of the audit.

3. Q: For a desktop or onsite audit, can I correct the claims being audited?

A: No. The pharmacy should not attempt to adjust or correct these claims on its own. Humana

will handle any adjustments to audited claims based on the final outcome of the audit.

4. Q: How will I be notified of a desktop or onsite audit?

A: Depending on your pharmacy‟s preference, either through e-mail or mail (UPS or certified

mail.)

5. Q: What should my pharmacy submit for a desktop audit?

A: As per section 3.2 of this audit guide, an original hard copy prescription (front and back), a

copy of the signature log or delivery manifest, and a compound worksheet if applicable. Also,

please provide the requested copy of the computer-generated hard copy label, and if applicable, a

copy of the administration record(s) for vaccines.

6. Q: If a compound prescription is in question, what should I submit?

A: In addition to the hard copy documentation, a compound worksheet including the NDC of

each ingredient, the cost of each ingredient and the quantity of each ingredient used in the

compound.

7. Q: How are compound prescriptions calculated?

A: Based upon the compound worksheet, the quantity and contract rate for each ingredient is

added together.

8. Q: Who should I send my documentation to for an audit?

A: To the pharmacy audit general account e-mail address, mailing address, etc. All

documentation should be submitted on unstapled, 8 ½ x 11 inch paper.

9. Q: What can my pharmacy do to prepare for an onsite audit?

A: The pharmacy should have all documentation from the previous 18-24 months readily

retrievable. In addition, Humana‟s onsite vendor will supply a range of prescriptions two to

three days prior to the audit. The prescription books associated with these prescriptions should be

in numerical order and readily retrievable prior to the audit.

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10. Q: Can my pharmacy be provided an exact list of prescriptions prior to an onsite audit?

A: No. To ensure the integrity of the audit, Humana‟s onsite vendor will not supply a list of

exact prescriptions until the date of the audit.

11. Q: Should I have a staff member assist during the onsite audit?

A: Yes. It is preferred that a staff member assist with the audit to ensure all documentation is

given to the auditor at the time of the audit.

12. Q: How can the audit deadline be extended?

A: It is expected that all documentation be submitted by the due date. However, Humana reviews

requests for extensions as requested by the pharmacy. If a pharmacy requests an extension after

the deadline has passed, Humana will not grant the extension.

13. Q: When can my pharmacy expect to receive an audit report?

A: To comply with state laws and contractual requirements, Humana strives to review audit

materials in a timely manner.

- For onsite audits, the initial finding report is typically sent within seven to 10 days of

the audit. The final audit report is typically sent within 30 days of the deadline.

- For desktop audits, all audit reports are typically sent within 30 days of the audit

deadline.

14. Q: What type of discrepancy can I supply additional documentation for during post audit?

A: As per section 6, the Humana Pharmacy Solutions audit discrepancy code list, outlines what

is acceptable for each discrepancy type during post audit.

15. Q: What type of discrepancy can I appeal?

A: An appeal can be submitted on any claim marked discrepant, as long as the appeal is filed

under the guidelines in section 6.2 of this audit guide, using the Pharmacy Audit Appeal Form.

16. Q: Who reviews my appeal?

A: The Humana Pharmacy Appeals Committee, which is composed of several associates from

numerous functional areas within Humana.

17. Q: My pharmacy provides other services such as delivery and drive-thru services to our patients.

For these members, rather than require the patient to sign a signature log, we write “mailed,”

“delivery” or “drive thru” to show that this prescription was delivered. Is this practice

acceptable?

A: No. The pharmacy handwriting “mailed,” “delivery,” “drive thru” or other interpretation does

not validate that a patient has his/her medication. The pharmacy should provide a delivery

manifest or patient statement. Humana does not accept the signature of the courier or delivery

driver as proof of delivery.

18. Q: Will I receive a final/estimated charge back amount with my audit result?

A: Yes. You will receive an estimated charge-back amount on all audit findings. The true and

final amount cannot be calculated until the claims are adjusted and will appear on the pharmacy

remittance statement.

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19. Q: How and when will recoupments/penalties take place if applicable?

A: Recoupments/penalties will take place within 30 calendar days of the audit closing, meaning

all appeals have been exhausted. Recoupments/penalties will be offset from future claims

payments.

20. Q: How long do I have to file an appeal?

A: Appeals must be submitted on an appeal form and postmarked within 15 calendar days from

the date of the final results letter.

21. Q: Who should I contact, with any questions about my audit?

A: For Humana desktop audits, call 502-580-3232 or e-mail [email protected]

For Humana onsite audits, call 215-551-3838

For Argus audits, please e-mail [email protected]

For appeals, please e-mail [email protected]