Aaron Musgrove-Lecours Director, Pharmacy Operations
FDR Oversight: How Do You Do it (or Not)? 2015 Compliance Institute
April 19, 2015
BUILDING THE PBM/VENDOR RELATIONSHIP
Selling the idea of partnership
1. The right thing is good for vendor, plan and members
2. Educate on your membership 3. Integration
4. Common Goals
• Engage your vendor in quality
• Get them to appreciate the connection to customer satisfaction and business growth
BUILDING THE PBM/VENDOR RELATIONSHIP
Selling the idea of partnership
1. The right thing is good for vendor, plan and members
2. Educate on your membership 3. Integration
4. Common Goals
• Share your organization’s story, have PBM share it with staff handling your account • Visit call centers, prior authorization
centers
• Speak with employees directly • Educate on your
membership-demographics, challenges, etc.
BUILDING THE PBM/VENDOR RELATIONSHIP
Selling the idea of partnership
1. The right thing is good for vendor, plan and members
2. Educate on your membership 3. Integration
4. Common Goals
• PBM staff- extension of your organization • Should share responsibility for your
BUILDING THE PBM/VENDOR RELATIONSHIP
Selling the idea of partnership
1. The right thing is good for vendor, plan and members
2. Educate on your membership 3. Integration
4. Common Goals
• Establish and emphasize shared goals • If organization’s membership is happy and
PBM performs well, plan will likely grow, increasing revenue for vendor and plan
YOUR ACCOUNT TEAM
BUILD THE RELATIONSHIP
MANAGE AS “ONE OF YOUR OWN”
MANAGE AS “ONE OF YOUR OWN”
Selling the idea of partnership
1. Weekly calls
2. Quarterly onsite visits 3. Clear expectations 4. Don’t abuse
5. Encourage proactive, collaborative relationship
• Operations • Clinical • Medicare
MANAGE AS “ONE OF YOUR OWN”
Selling the idea of partnership
1. Weekly calls
2. Quarterly onsite visits 3. Clear expectations 4. Don’t abuse
5. Encourage proactive, collaborative relationship
• Tour site and make note of operations • Interview operational staff familiar with
your account
• Review training programs • Meet with management • Provide information about your
MANAGE AS “ONE OF YOUR OWN”
Selling the idea of partnership
1. Weekly calls
2. Quarterly onsite visits 3. Clear expectations 4. Don’t abuse
5. Encourage proactive, collaborative relationship
• How quickly do you expect a response? • Must some responses be handled faster
than others?
• Email and return call expectations • Establish who should be making requests
of account team
• Check-in on workload: opportunities for more self-sufficiency?
MANAGE AS “ONE OF YOUR OWN”
Selling the idea of partnership
1. Weekly calls
2. Quarterly onsite visits 3. Clear expectations 4. Don’t abuse
5. Encourage proactive, collaborative relationship
• “Catch more with honey”
• Limit wasteful, time consuming requests • Utilize client tools
• Frees team to handle requests you can’t do yourself
• Automated report delivery • Limit ad hoc report requests
• Set up subscriptions for special report requests
• Reports can take a lot of time from your account team’s day, cutting into time to address other issues
MANAGE AS “ONE OF YOUR OWN”
Selling the idea of partnership
1. Weekly calls
2. Quarterly onsite visits 3. Clear expectations 4. Don’t abuse
5. Encourage proactive, collaborative relationship
• Frequent engagement with account team • Set clear goals
• Solicit input from account team to help achieve these goals
• Set tone of transparency
• Shared risk from a business perspective • Collaboration is key
• Large PBM often has more resources to leverage and this benefits both parties
• Philanthropic opportunities
VENDOR OVERSIGHT
VENDOR OVERSIGHT
Areas of Oversight
1. Call Centers 2. Prior Authorizations
3. Reject and Paid Claims Review 4. Site Visits
5. Formulary Administration and Pricing
• Listen to calls
• Have PBM inform their staff you are listening to calls
• Monitor metrics
• Set expectations for call center metrics across all lines of business • Medicare is good benchmark
VENDOR OVERSIGHT
Areas of Oversight
1. Call Centers 2. Prior Authorizations
3. Reject and Paid Claims Review 4. Site Visits
5. Formulary Administration and Pricing
• Letter Review • Decision Review • Turn-around times
VENDOR OVERSIGHT
Areas of Oversight
1. Call Centers 2. Prior Authorizations
3. Reject and Paid Claims Review 4. Site Visits
5. Formulary Administration and Pricing
• Reject claim review daily for Medicare • Protected class follow-through • Reject and Paid claim review weekly for
other lines of business
• Reject review for oversight of formulary administration
• Paid claim review for oversight of formulary administration
• Coding errors= recoverable dollars
VENDOR OVERSIGHT
Areas of Oversight
1. Call Centers 2. Prior Authorizations
3. Reject and Paid Claims Review 4. Site Visits
5. Formulary Administration and Pricing
• Call Centers • PA Centers • Specialty • Mail Order
VENDOR OVERSIGHT
Areas of Oversight
1. Call Centers 2. Prior Authorizations
3. Reject and Paid Claims Review 4. Site Visits
5. Formulary Administration and Pricing
• Formulary Updates on website
• Submission of formulary to State and CMS • Audit of pricing and formulary
• Coding errors and pricing errors frequent with PBMs
VENDOR OVERSIGHT
Areas of Oversight
6. Fraud, Waste and Abuse 7. Financials
8. Clinical Programs
9. Pharmacy Network/ other subcontracting 10.Policy and Procedures
• Establish relationship between SIU and PBM’s FWA unit, keep compliance officer involved
• Ride along on pharmacy audits
VENDOR OVERSIGHT
Areas of Oversight
6. Fraud, Waste and Abuse 7. Financials
8. Clinical Programs
9. Pharmacy Network/ other subcontracting 10.Policy and Procedures
• Prior Auth. Billing • Clinical Programs Billing
• Invoice- Claims and Admin Billing
VENDOR OVERSIGHT
Areas of Oversight
6. Fraud, Waste and Abuse 7. Financials
8. Clinical Programs
9. Pharmacy Network/ other subcontracting 10.Policy and Procedures
• Meeting clinical objectives • Meeting ROI’s
VENDOR OVERSIGHT
Areas of Oversight
6. Fraud, Waste and Abuse 7. Financials
8. Clinical Programs
9. Pharmacy Network/ other subcontracting 10.Policy and Procedures
• Attestation of compliance for downstream entities
• Attestation of credentialing and re-credentialing
VENDOR OVERSIGHT
Areas of Oversight
6. Fraud, Waste and Abuse 7. Financials
8. Clinical Programs
9. Pharmacy Network/ other subcontracting 10.Policy and Procedures
• Track and collect • Review Yearly
TRACKING YOUR SUCCESS
AM I GETTING ANYWHERE?
TRACKING YOUR SUCCESS
Areas of Oversight
1. Monitoring 2. Document Everything 3. Stay Organized 4. Trends 5. Internal Audits • Daily • Weekly • Monthly • Quarterly • AnnuallyTRACKING YOUR SUCCESS
Areas of Oversight
1. Monitoring 2. Document Everything 3. Stay Organized 4. Trends 5. Internal Audits • CAPS • Oversight • ReportingTRACKING YOUR SUCCESS
Areas of Oversight
1. Monitoring 2. Document Everything 3. Stay Organized 4. Trends 5. Internal Audits • Shared Folders• Central Location for all documents • Set a naming convention
TRACKING YOUR SUCCESS
Areas of Oversight
1. Monitoring 2. Document Everything 3. Stay Organized 4. Trends 5. Internal Audits• Areas with recurring issues • Areas with no issues
• Eliminate or reduce oversight
TRACKING YOUR SUCCESS
Areas of Oversight
1. Monitoring 2. Document Everything 3. Stay Organized 4. Trends 5. Internal Audits• Is your program working?
• Can you provide information to regulatory entities efficiently?
• Surveying your membership • Specialty
• Benefit