INSIGHT - Summer 2020

Summer 2020 | 18 PAAS National ® Opportunities and C with COVID-19 Trenton Thiede, Pharm.D., MBA, COO – PAAS National Since the onset of the COVID-19 public health crisis, PAAS National has continued to design and implement tools for our members to help them navigate this time and prepare them for the future. In this unchartered environment, there have been many frequently asked questions, but two stand out. Our members want to know how to get started with COVID-19 Point-of-Care Testing (POCT) and they’re interested in how to handle a recent surge in onsite audits. Point-of-Care Testing The Department of Health and Human Services (HHS) has issued guidance stating licensed pharmacists may order and administer COVID-19 tests without patient-specific prescriptions or a Collaborative Practice Agreement. 1 On May 19, 2020, the Advisory Opinion declared this guidance supersedes state laws that would otherwise prohibit pharmacists from providing POCT. 2 Community pharmacies can play a vital role in the identification of active COVID-19 infections. Plus, this is a tremendous opportunity for pharmacists to provide additional clinical services, showing payers they’re ready to take on challenges associated with expanded services that allow for reimbursement. Getting Started Here’s a brief overview of the steps needed to get started with POCT. 1. Check with a professional liability carrier to ensure coverage for POCT. 2. Have a bloodborne pathogen exposure control plan and train staff accordingly to ensure safety. 3. Ensure staff is trained on appropriate POCT procedures. 4. Obtain or modify the Clinical Laboratory Improvement Amendments (CLIA) certificate of waiver. 5. Consider obtaining a Type 1 NPI number to support claims billing. 6. Consider enrollment as a Medicare Part B Provider. 7. Select instruments and test kit for procurement. Members are encouraged to visit the PAAS portal for an in-depth, step-by-step document found under the Tools & Aids section. Note : Authority to provide COVID-19 testing under the federal Public Readiness and Emergency Preparedness (PREP) Act lasts for the duration of the public health emergency, and then it defers to state laws. Onsite Audits Onsite audit notices from a few PBMs, most notably Caremark ® and EnvisionRx ® (performed by SCIO Health Analytics ® ), have increased. Most of the Caremark audit notices include a “COVID-19 Modifications” instruction page that indicates the audit will be converted into a remote review (like a desk audit) and that documentation may be submitted by fax, secure email, or mail. These audits have requested anywhere from 50-140 prescriptions (with back sticker or patient label) and 10-50 signature logs. In a few instances, Caremark indicated that pharmacies have the option to complete an exit interview remotely or have the auditor visit the pharmacy. EnvisionRx audit notices include a “Special Notice Regarding COVID-19” that states onsite auditors will do a self-health assessment and temperature check before entering the pharmacy and wear a face mask and gloves at all times.