Effective January 1, 2022, at least one of the major PBMs has updated language related to the billing of specific NDC numbers the PBM considers “Aberrant.” The revised list of NDCs was sent to network pharmacies and includes a list of “Practices and Trends” prohibiting dispensing activities. The revised language, while vague, creates multiple pitfalls that could potentially lead to financial chargeback and/or the termination of your PBM contract. The revised language creates prohibitions on dispensing activities deemed “inconsistent” as determined solely by the PBM. Additionally, your pharmacy’s purchasing practices, use of patient information, pharmacy programs, and overall pharmacy practices will be even further scrutinized, and may have severe financial or contractual consequences if the PBM determines any of these activities to be “Aberrant.” The time to evaluate and determine your pharmacy’s risk exposure is now. Contact Boesen and Snow Law to consult with our firm on risk analysis and compliance measures.
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