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Audit Issues and Resolutions: It has been brought to our attention that some auditors are attempting to recoup the full amount of computer generated refill rx's and all of their refills. They are doing this on the basis that by definition a phone order must be "reduced to writing". The NJ State Board of Pharmacy has changed the language to include "any expression by letters, numbers, or characters, including handwriting, printing, typewriting, lasered, electronic or other tangible form of recording." This new regulation has not been written yet. Click here for The Board of Pharmacy Minutes that ruled on this issue. (Item 3 under Old Business) Audit Advisor (America's Pharmacist) 11/08 Q: If a physician writes a prescription for a single source brand drug and indicates "DAW 1," should I go ahead and bill the prescription as "DAW 1?" A: The best option is to bill the prescription as DAW 0. On occasion, a physician will indicate "DAW" on a single-source brand drug even though there is no generic substitute available. Such situations should be billed online as a "DAW 0." Billing as a "DAW 1" may flag you for an audit (excessive DAW 1s) and may also count against you in tabulating PBM generic utilization incentives. A caveat does exist on refill prescriptions for brand drugs that have become available generically since the original fill date. In this situation, the original hard copy should be retrieved and reviewed or the physician called for a new prescription that specifies the current DAW status. Remember, it is safest to bill single-source products as "DAW 0."
10/08 Q: Doctors write insulin prescriptions "as directed" and third party auditors are interested in how many vials on insulin my patients receive. How do I protect myself in an audit situations? A: Patients receiving more than two vials per month may create an audit flat that will result in an onsite audit of your pharmacy. While it is possible for a patient to use large amounts of insulin, this parties view three or more vials as unusual/ They believe that pharmacies may allow a patient to stockpile insulin. Take extra care whenever a patient is using three or more vials of insulin per month. Instead of "As Directed" for directions, provide detailed information on dosing parameters. Remember to accurately calculate and transmit the correct days supply. You can bet that an auditor will select these prescriptions to review during an onsite audit. If the amount of insulin your pharmacy dispensed for a patient is justified by the documentation on the hardcopy prescription, you should not have a problem. If all your prescriptions state "As Directed" expect aggressive challenges from the third party. 09/08 Q: Are there any special precautions to take on oral or telephone prescriptions that are billed to third parties? A: Taking oral presciption orders can present
special audit problems and challenges. All verbal prescription orders must
contain at least the minimum information as legally required on any
prescription, including:
If someone other than the doctor phones in the prescription, it is a good idea to note the name and title of the person calling. Thirs parties, in an audit situation, are penalizing pharmacies for oral prescription orders failing to contain the requisite information. For instance, many pharmacies neglect to properly indicate or check DAW/BMN on verbal prescriptions that physicians specify brand product only. When a telephone prescription does not contain the correct DAW information, auditors view prescriptions as eligible for generic substitution. Many third parties will not allow any subsequent documentation after the fact to reverse their findings. Please avoid any problems by making sure procedures are in place to sufficiently document all required informataion and actions concerning any verbal prescription orders.
08/08 Q; My Pharmacy is scheduled for a third party audit. What records is the auditor entitled to review? A: In most cases, third party auditors are entitled to review hard copy prescription records and usually signature logs for the services your pharmacy billed to them. The records of other patients from other plans and coverage are confidential and the auditor should be restricted from accessing them. In face the HIPAA privacy rules enforces limits placed upon PHI. You are responsible for the PHI in your pharmacy and as such, you would be responsible for any breaches by an auditor. This means only you and your staff should pull hard copy prescriptions for the auditor. A more in-depth answer to which records must be made available to the third party is found in your provider agreement and plan manual. Go back to these documents to carefully read what you are contractually agreed to allow a third party to review. Third-party provider agreements are more complex, detailed, and demanding than ever before. It is essential to read and understand all contracts in their entirety before signing them. 06/08 Q: In a recent audit, my pharmacy received alot of discrepancies for prescriptions written "As Directed." Is this a fair audit practice? A: Fairness in this situation is a question of opinion. Prescriptions written, "as directed," can increase a pharmacy's risk in audit situations. Whether you believe its fair or immaterial; third parties are citing these claims and taking money away from pharmacies unless they provide documentation to support the quantities dispensed. Third parties are interested in controlling plan maximums in terms of days supply and quantity of medication dispensed. "As directed" prescriptions create ambiguity and challenges for third parties in policing these parameters. The safest procedure for the patient and third-party billings is to contact the prescribing physician for a clearer definition. If it isn't convenient to contact the physician, ask the patient how often they take their medication. Don't forget to DOCUMENT this information on the hard copy prescription. Make sure dispensing quantities stay within therapeutic guidelines. If "as directed" is used to skirt plan limitations, you are creating a ticking time bomb. PBMs are becoming more clever at flagging excessive quantities and in some cases contacting physicians to verify dosages. Resist patients who place unfair pressure upon you to boost dispensing limits. In an audit the U.D. designation maybe translated by the PBM into much lower quantities than you are dispensing. Pay particular care on expensive brand name medications. PBMs are also going after insulin, syringe, inhalers, and glaucoma drop quantities on "as directed" prescriptions. 04/08 Q: What is the safest method for billing third party prescriptions? A: A money saving tip for community pharmacists is to "fill and bill prescriptions as the doctor writes them and with the correct days supply." Many pharmacies are needlessly penalized during audits for cutting or increasing prescribed quantities without the appropriate documentation. These errors, couples with submitting and incorrect days supply, can lead to major headaches and large recoupment payments to third paries. Transmit prescriptions exactly as written by the physician, with the correct quantity and number of days' supply. If the quantity or days' supply exceeds plan limitations, you will be charged back in an audit. If you dispense a quantity great thn what was written (even if the plan allows for larger quantities) you will be charged back in an audit. If the physician authorizes a change in quantity, directions, or refills; PAAS strongly recommends thats a new prescription be created (per your states laws) instead of amending the old order. Every month dollars are needlessly returned to third parties due to complacency with this issue. Remember that extra effort today may save big money in the future. Take it seriously.
02/08 Q: If a physician writes a prescription for a single source brand drug and indicates "DAW 1," should I go ahead and bill the prescription as "DAW 1?" A: The best option is to bill the prescription as DAW 0. On occasion, a physician will indicate "DAW" on a single-source brand drug even though there is no generic substitute available. Such situations should be billed online as a "DAW 0." Billing as a "DAW 1" may flag you for an audit (excessive DAW 1s) and may also count against you in tabulating PBM generic utilization incentives. A caveat does exist on refill prescriptions for brand drugs that have become available generically since the original fill date. In this situation, the original hard copy should be retrieved and reviewed or the physician called for a new prescription that specifies the current DAW status. Remember, it is safest to bill single-source products as "DAW 0." 01/08 Q: My pharmacy is scheduled for a third-party audit. What records is the auditor entitled to review?? A: In most cases, third party auditors are entitled to review hard copy prescription records and usually the signature logs for the services your pharmacy billed to them. The records for other patients and other plans and coverage's are confidential and the auditor should be restricted from accessing them. In fact the HIPAA Privacy Rule enforces limits places upon PHI (personal health information). You are responsible for the PHI in your pharmacy and as such, would be responsible by any breach made by an auditor. A more in depth answer to which records must be made available is found in your provider agreement and plan manual. Go back to these documents and carefully read what you contractually agreed to allow a third party to review. Third-party provider agreements are more complex, detrailed and demanding than ever before. It is essential to read and understand all contracts in their entirety before signing them. 12/07 Q: In a recent audit, my pharmacy received a lot of discrepancies for prescriptions written "As Directed." Is this a fair audit practice? A: Fairness in this situation is a question of opinion. Prescriptions written, "AS DIRECTED," can increase a pharmacy's risk in an audit situation. Whether you believe it's fair or immaterial; third parties are citing these claims and taking money away from pharmacies unless they provide documentation to support the quantities dispensed. Third Parties are interested in controlling plan maximums in terms of days supply and quantity of medication dispensed. "as directed" prescriptions create ambiguity and challenges for third parties in policing these parameters. The safest procedure for the patient and the third party billings is to contact the prescribing physician for a clearer definition. Don't Forget to document this information on the hard copy prescription. Make sure dispensing quantities stay within therapeutic guidelines. If "as directed" is used to skirt plan limitations, you are creating a ticking time bomb. PBM's are becoming more clever at flagging excessive and illogical quantities and in some cases contacting physicians to verify dosages. Resist patients that put unfair pressure on you to boost dispensing limits. In an audit the U.D. designation may be translated by the PBM into much lower quantities than you are dispensing. Pay particular care on expensive brand name medications. PBMs are also going after insulin, syringes, inhalers, and glaucoma drop quantities on "as directed: prescriptions.
11/07 Q: What is the safest method for billing 3rd party prescriptions? A: A money saving tip for community pharmacies is to "fill and bill prescriptions as the doctor writes tem with the correct days supply." Many pharmacies are needlessly penalized during audits for cutting or increasing prescribed quantities without appropriate documentation. These errors, coupled with submitting the incorrect days supply, can lead to major headaches and large recoupment payments to third parties. Transmit prescriptions exactly as written by the physician, with the correct quantity and days supply. If the quantity or days supply exceeds plan limitations, you will be charged back in an audit. If you dispense a quantity that is greater than written on the prescription (even if the plan allows for larger quantities) you will be charged back in an audit. If a physician authorizes a change in quantity, directions or refills, PAAS strongly recommends that a new prescription be created (per your state's laws) instead of amending the old order. Every month dollars are needlessly returned to third parties due to complacency with this issue. Remember that the extra effort today may save big money in the future. Take it seriously.
10/07 Q: If a physician writes a prescription for a single source brand drug with a "DAW 1, " should I go ahead and bill the prescription as a "DAW 1?" A: The best option is to fill the rx as "DAW 0." On occasion a doctor will indicate "DAW" on a single source brand drug even though there is no generic substitute available. Such situations should be billed online to the third party as "DAW 0." Billing single source drugs as "DAW 1" could flag an audit (excessive DAW 1s) and may count against you in tabulating PBM generic utilization incentives. A caveat does exist on refill prescriptions for brand dugs that have become generically available since the original fill date. In this situation, the original copy of the rx should be retrieved and reviewed or the physician called for a new prescription that specifies the current DAW status. Remember it is safest to bill single source brand drugs as "DAW 1." 9/07 Q: My pharmacy is scheduled for a third party audit. What records are the auditor entitled to review? A: In most cases, third party auditors are entitled to review hard-copy prescription records and usually signature logs for the services your pharmacy billed to them. The records of other patients from other plans and coverages are confidential and the auditor should be restricted from accessing them. In fact the HIPAA Privacy Rule enforces limits placed upon (PHI). You are responsible for the PHI in your pharmacy and as such, you would be responsible for any breaches by an auditor. This means only you or your staff should pull hard-copies for the auditor. A more in-depth answer to which records must be made available to the third party is found in your provider agreement and plan manual. Go back to these documents to carefully read what you contractually agreed to allow a third party to review. Third-party provider agreements are more complex, detailed and demanding than ever before. It is essential to read and understand all contracts in their entirety before signing them.
8/07 Q: Are pharmacy audits on the increase? What should I expect if my pharmacy is audited? A: Third-Party audits happen much more frequently than you might realize. According to tabulations put together by PAAS National for 2006, there were 93 audits for every 100 community pharmacies. Since Medicare Part D, the number of audits per pharmacy have more than doubled. The average audit is 2006 resulted in a recoupment order of $10, 021.88. This is the initial amount that third parties attempt to extract from pharmacies as a charge-back fir alleged audit discrepancies. Not only is the frequency of audits increasing , PBMs and plan sponsors continue to invent clever new methods to harvest potentially discrepant pharmacy claims to review for potential charge-backs. Companies that specialize in pharmacy audits are proliferating at a rapid rate. PAAS works with their member pharmacies to defend themselves against these sizable audit challenges. Each third party has their own unique set of discrepancies they look for in audits. PAAS is skilled in assisting pharmacies with documentation requirements and in helping members to exercise their rights to due process. PAAS reduced average charge-backs by 81.2% in 2006. Results vary by individual situation. 6/07 Q: What types of filling and billing activities can flag a pharmacy for a third-party audit? A: PBMs are developing more sophisticated detection techniques to find flaws in prescription claims. Keep in mind, when your pharmacy is selected for an audit, it is because you fall outside of the third-party norm. With online adjudication, third parties create subterranean audit networks, constantly monitoring your filling behavior an dispensing patterns. Third parties constantly create new algorithms to harvest claim data. Activities that can flag an audit include (but certainly aren't limited to) the following: certain percentages of DAW 1 use, refill patterns, generic substitution, average of prescription costs, large amounts of compounded prescriptions, and frequent claim overrides. 5/07 Q: When a patient requests the brand drug over the generic, should I document patient requests as DAW 2 prescriptions? A: Auditors are becoming more interested than ever for patient requested brand drugs, DAW 2. It is a wise move to document prescriptions transmitted as DAW 2. Third parties will scrutinize this dispensing category and looking for problems. Several Third Parties are penalizing pharmacies in audits when they cannot supply documentation for patient requested brand named dispensing when lower cost multi-source products are available. It may be prudent to ask the patient to initial and date the "DAW2" on the original prescription. Some pharmacies use a rubber stamp and then collect the patient's initials to document DAW 2 dispensing. Patients often try to convince pharmacists to transmit these types of prescriptions as DAW 1. This is a sure path for problems. A DAW 1 indicates that the doctor has ordered the brand, not the patient. A patient requested brand drug (when generic is available) should always be transmitted as a DAW 2. Remember a little effort now can limit your risks in an audit situation down the road. 4/07 Q: What is the safest method for billing third-party prescriptions? A: A money saving tip to community pharmacists is to "fill and bill prescriptions as the doctor writes them with the correct days supply." Many pharmacies are needlessly penalized during audits for cutting or increasing prescribed quantities without the appropriate documentation. These errors, coupled with submitting the incorrect days supply, can lead to major headaches and larger recoupment payments to third parties. Transmit prescriptions exactly as written by the physician, with the correct quantity and number of day's supply. If the quantity or day's supply exceeds plan limitations, you will be charged back in an audit. If a physician authorizes a change in quantity, directions or refills; PAAS recommends that a new prescription be created (per your state's laws) instead of amending the old order. Every month dollars are needlessly returned to third parties due to complacency with this issue. Remember that extra effort today may save big money in the future. Take it seriously. 3/07 Q: If a physician write a prescription for a single source brand drug and indicate "DAW 1," should I go ahead and bill the prescription as a DAW 1? A: The best option is to fill the prescription as a DAW 0. On occasion, a physician will indicate "DAW" on a single source brand drug even though a generic substitute is not available. Such situations should be billed online to the third party as "DAW 0." Billing single source drugs as "DAW 1" may flag you for an audit (excessive number of DAW1's) and may also count against you in tabulating PBM generic utilization incentives. A caveat does exist on the refill prescriptions for brand drugs that have become available generically since the original fill date. In this situation, the original hardcopy should be retrieved and reviewed or the physician called for a new prescription the specifies the current DAW status. Remember , it is safest to bill single source brand drugs as "DAW 0." 2/07 Q: I recently had an audit, the auditor was a real stickler with my signature logs. Why are signature logs so important? A: Money lost due to incomplete signature logs is a high ranking third party discrepancy. Signature logs should be handled and treated with the same care and respect as the original hard-copy prescriptions; using an approved form , ad being filed chronologically, checked for completeness and stored in a safe area. The primary function of a signature log is to verify the delivery and receipt of services to patients. The log form should contain appropriate release information, and the NCPDP approved disclaimer. If your log contains these clauses and space for appropriate patient and prescription information, it should be acceptable to all major third parties. Additionally, a well-designed log can incorporate space for the HIPAA required patient acknowledgement of the receipt of you pharmacy's Notice of Privacy Practices (NOPP). You must provide your NOPP to each patient on the first date of service and collect a written acknowledgement from each patient of the receipt of your NOPP. These written acknowledgements must be maintained in a retrievable record for 6 years. Many pharmacies are adding electronic signature logs to their pharmacy software. As long as the patient receives the appropriate disclaimers and releases, audits can be a breeze. Electronically stored signatures are easily retrieved. While a signature log is not the only method to document the delivery of services, well-kept signature logs make life much easier during an audit situation. Put these practices into play and you will be one step ahead of the audit game. 1/07 Q: An auditor came into my store ad claimed that some of my prescriptions were invalid because the physican DEA number was on the back of the hard copy. Is there a requirement for DEA numbers to appear on the face of the prescription? A: NO! It is not necessary for a DEA number to be appear on the face of the prescription. A DEA number is only required on prescriptions written for controlled substances. Additionally, there is no federal requirement for this number to appear on a particular spot on a prescription, front or back. With telephone prescriptions, pharmacies often rely upon a computer label stuck to the back of the prescription to supply the correct DEA number. If an auditor attempts to claim this as an invalid prescription, they are incorrect. 12/06 Q: In a recent audit, my pharmacy received a lot of discrepancies for prescriptions written "as directed." Is this a fair audit practice? A: Fairness in this situation is a question of opinion. Prescriptions written "as directed" can increase a pharmacy's risk in audit situations. Whether you believe it's fair is immaterial; third parties are citing these claims and taking money away from pharmacies unless the provide documentation to support the quantities dispensed. Third parties are interested in controlling plan maximums in terms of days supply and quantity of medication dispensed. " as directed" prescriptions create ambiguity and challenges for third parties policing these parameters. The safest procedure for the patient and third-party billings is to contact the prescribing physician for a clearer definition. If it isn't convenient to ask the physician ask the patient how often they take their medication. Don't forget to DOCUMENT this information on the hard copy prescription. Make sure dispensing quantities stay within the dispensing guidelines. If "as directed" is used to skirt plan limitations , you are creating a ticking timebomb. PBM's are becoming more clever at flagging excessive and illogical quantities and in some cases contacting physicians to verify dosages. Resist patients that place unfair pressure on you to boost dispensing limits. In an audit the UD designation may be translated by the PBM into much lower quantities then you are dispensing. PBMs are also going after insulin, syringes, inhalers, and glaucoma drop quantities on "as directed" prescriptions. 11/06 Q: When I use an override code to force an early refill, do I really have to document the override code I use? A: From time to time nearly all third parties have audited the documentation of override codes for appropriate use in a situation. This is especially true with Medco Health. Medco continues to get tougher on pharmacies, auditing their use of override codes. Pharmacies are cautioned to follow Medco Health's documentation requirements when using one of the codes to obtain an adjudicated claim. These codes include 03 for Vacation Supply Early Refill, 04 for Lost or Spilled Medication Early Refill, 05 for Dosage or Therapy Change, and 02 for Maximum Daily Dosage Exceeded. For audit purposes document the reason for any override on the hard copy prescription, and if any applicable include the authorization override code given by the third party. Additionally, double check your pharmacy dispensing software to ascertain how it handles override codes. Several pharmacies have reported software glitches. Some systems apparently hold an override code and continue to transmit the same override on subsequent fills, even though the prescription isn't being refilled early. This is a big audit flag that could cost your pharmacy a lot of money. 10/06 Q: Doctors write insulin prescriptions "As Directed: and third party auditors are interested in how many vials of insulin my patients received. How do I protect myself in an audit situation? A: Patients receiving two or more vials of insulin per month may create an audit flag that will result in an audit. While it is possible for a patient to use large quantities of insulin, third parties view two or more vials as unusual. Instead of using "As Directed" for directions, obtain detailed information on dosing parameters. Remember to accurately calculate and transmit the correct days supply. You can bet that an auditor will select "As Directed" prescriptions for multiple vials of insulin to view on an onsite audit. If the amount of insulin your pharmacy dispensed to the patient is justified by the documentation on the hard copy prescription, you should not have a problem. If all your insulin prescriptions state "As Directed" expect aggressive challenges from the third party. 9/06 Q: When should I select DAW 5 to transmit a third-party prescription? A: In instances where branded items are purchased at generic prices and used as your pharmacy's generic, select DAW 5. When a third party receives a DAW 5 transmission , they understand your use of a branded item as a generic. You will receive more favorable reimbursements then using DAW 0 or DAW 1. As an example, When Caremark calculates bonus payments for their Generic Performance Incentive Program (GPI) they count the BRANDED version of a multi-source drugs filled as DAW 0 or DAW 1 against the pharmacy. When the drug is keyed as DAW 5, Caremark credits the pharmacy as substituting and dispensing a generic drug. Keep in mind that reimbursement on DAW 5 transmissions will typically be MAC'd. Remember, for branded items used as your generic, select DAW 5. 8/06 Q: I transmit a high number of DAW 1 prescriptions as I have a lot of patients with union plans that have the same copay for brands and generics. Will this trigger an audit? A: Yes. Limit DAW 1 transmissions by remembering:
7/06 Q: When the patient requests the brand drug over the generic should I document patient requests as DAW 2 on the prescriptions? A: Auditors are becoming more interested in patient requested brand drugs, DAW 2. It is a wise move to document prescriptions transmitted as DAW 2. Third parties will scrutinize this dispensing category and are looking for problems. Several third parties are penalizing pharmacies in audits when they cannot supply documentation for patient requested brand named dispensing when a lower cost multi-source products are available. It may be prudent to ask the patient to initial and date the word "DAW 2" on the prescription. Patients often try to convince the pharmacists to transmit these types of prescriptions as DAW 1. This is a sure path to problems. A DAW 1 indicates that the doctor has ordered the brand, not the patient. A Patient requested brand drug (when generic is available) should always be transmitted as DAW 2. 6/06 Q: I recently had an audit, and the auditor was a real stickler with my signature logs. Why are the signature logs so important? A: Money lost due to incomplete signature logs is a high ranking third party audit discrepancy. Signature logs should be handled with the same care and respect as the original hard-copy prescriptions; using an approved form, being filed chronologically, checked for completeness and stored in a safe area. The primary function of a signature log is to verify the delivery and receipt of services to patients. The log form should contain the appropriate patient release of information and the NCPDP approved disclaimer. If your log contains these clauses and space for appropriate patient and prescription information, it should be acceptable to all major third parties. Additionally, a well-designed log can incorporate space for the HIPAA required patient acknowledgements of the receipt of your pharmacy's Notice of Privacy Practices (NOPP). %These written acknowledgements must be maintained in a retrievable record for 6 years. Many pharmacies are adding electronic signature capture to their pharmacy computer systems. As long as the patient receives the appropriate disclaimers and releases, audits can be a breeze. Electronically stored signatures are easily retrieved. While a signature log is not the only method to document the delivery of services, well-kept signature logs make life much easier during any audit situation. Put these practices into play and you will be one step ahead of the audit game. 5/06 Q: Are there third party pitfalls when trading inventory with other pharmacies? A: Many pharmacies have cooperative relationships with other pharmacies located in their trade area, selling and exchanging pharmaceuticals on an emergency basis. The professional courtesy extended by one pharmacy to another can help save business and improve the quality of patient care. However, I caution pharmacists to keep accurate records and invoices of all such trades. In audits when third parties require pharmacies to prove their purchases of inventory, the swapping activities between pharmacies can cause problems. Many pharmacies have no records of the item, date and quantity of what procured from another pharmacy. As many third parties frown upon after-the-fact record keeping, I highly recommend that accurate transfer logbooks with invoice slips be kept. A little extra time and effort to maintain there records can save big money in an audit situation. 4/06 Computer Access to Auditors Q: An auditor asked to use one of my pharmacy computer terminals to access information. Should I allow the auditor to operate my pharmacy system? A: Absolutely not!!! Some third parties and auditors may insist on accessing information from your pharmacy computer system. Only an employee of the pharmacy should access any information viewed. Additionally, only the records of patients covered by the third party conducting the audit should be viewed. An auditor is not authorized to view other patient prescriptions and computer records--this includes daily logs. The HIPAA Patient Privacy and Security Regulations hold you, the covered entity responsible for such activity. You must maintain patient confidentiality and cannot reveal information without the proper release from the patient. Auditors should not be allowed to operate your computer system. 2/06 Obsolete NDC Numbers Q: Why do third parties accept claims filed on obsolete or old NDC numbers? A: Once an NDC number has been superseded or replaced with a new number, a third party cannot project how long the product with the old number will remain in pharmacies. So they accept the NDC number indefinitely--but keep in mind they typically do not update pricing to match the current market value. If the price isn't updated it means lower reimbursements to your pharmacy. Many pharmacists miss this switch when it occurs and fail to add the new NDC to their prescription dispensing software systems. A number of pharmacists are purchasing "pre-editing" services to help catch and correct this problem. All pharmacists are cautioned to make sure they are using current NDC numbers on their transmission to all third parties. When in doubt you should check for a newer NDC replacement. Remember, your safest practice is to fill and bill the NDC from the container you dispense. 12/05 DEA Number--Front or Back? Q: During a recent audit some of the Schedule II prescriptions were ruled invalid because the physician's DEA number was on the back and not the face of the prescription. Is this fair? A: In this case, NO--never assume that an auditor is always right, especially when it involves an interpretation of pharmacy practice laws. Nothing in federal law specifies the location of a DEA number on a Schedule II or Controlled Substance prescription -just that it must be on the rx. State law could invoke a more stringent standard but in your situation--Wisconsin law does not. Therefore the auditor's inference is incorrect and those discrepancies should be removed from your audit report. |