It is that time of year again; flu shot season is upon us. As busy as this season can be, we know you do not want to worry if you have all the documentation you need in case of an audit. Make it easy on yourself by ensuring you are ready now by following PAAS National®’s best practices to reduce your risk of audit recoupment.

What you will need for an audit:

1.   Authority to administer
•   A signed order from an authorized prescriber
•   A signed protocol that is up to date and includes specific vaccination(s) to be administered or a Collaborative Practice Agreement (CPA)

          o   When using a protocol or CPA, create a placeholder prescription with all prescription elements
•   In states where pharmacists have independent authority to vaccinate, create a placeholder prescription with all prescription elements
2.   Vaccination Information Statement (VIS)
•   Required to be given to patient prior to each administration
•   Be sure you have the most current VIS forms
3.   Screening Checklist
•   Not requested by PBMs, however should be retained for your records
4.   Vaccination Administration Record (VAR)
•   Date of Administration
•   Name of vaccine administered and manufacturer
•   Lot and Expiration Date of vaccine given
•   Site of administration (i.e. right arm)
•   Signature or initials and title of person administering
•   What VIS form was given

o   Date printed on the VIS
o   Date the VIS was given to the patient or parent/guardian

VAR and VIS forms, and information regarding what the CDC requires for health care providers to record, can be found on the CDC website1.

PAAS Tips:

• Check dates and vaccine types on your protocols to ensure they are up-to-date
• Have current VIS forms printed for each vaccine you administer
• Have VAR forms printed and educate all staff on how to complete the forms
• All vaccines should be submitted using days’ supply of “1” per NCPDP recommendations
• All vaccines administered via protocol should be submitted with origin code of “5” (pharmacy created) per NCPDP recommendations
• Be sure correct metric quantity is billed
• Keep vaccine documents stored in a system that makes access easy in case of an audit
• When billing for vaccine clinics, DO NOT bill prior to the vaccine being administered
• You may submit claims after the date of service, but the date of administration must be correct on the claim
• PAAS has seen pharmacies flagged for billing claims outside regular pharmacy hours – consider billing for vaccine clinics during regular business hours

PAAS National® is committed to serving community pharmacies and helping keep hard-earned money where it belongs. Contact PAAS today at (608) 873-1342 or info@paasnational.com to see why PAAS Audit Assistance membership might be right for you.

By Trenton Thiede, PharmD, MBA, President at PAAS National®, expert third party audit assistance and FWA/HIPAA compliance.
Copyright © 2023 PAAS National, LLC. Unauthorized use or distribution prohibited. All use subject to terms at https://paasnational.com/terms-of-use/.

References:
1.   https://www.cdc.gov/vaccines/hcp/admin/document-vaccines.html