Rx Signature Requirements
Interim Changes in Rx Signature Requirements
On March 20, the Centers for Medicare and Medicaid Services issued a memorandum stating that during the current COVID-19 crisis, it is suspending the requirement that pharmacies obtain a patient signature for the dispensing of drugs in a Medicare Part D plan. The statement said, in part, "requiring a patient signature for receipt of medication could undermine current public health efforts to combat the spread of the coronavirus. We are making clear that HHS does not require and will not audit for patient signatures as proof of delivery for any medications, including for controlled substances. Part D sponsors should work with pharmacy benefit managers and other entities to continue to utilize tools at their disposal to make sure beneficiaries are receiving controlled substances appropriately."
Shortly after the release of the CMS statement, both OptumRx and CVScaremark issued guidance statements on signature requirements in Part D plans.
OptumRx has waived the signature requirement for mailed medications, effective March 1 until further notice. See the Actual Optum Notice
- The delivery logs of affected claims should be documented with the verbiage "Impacted by COVID-19" as well as a means to tie the signature log to the specific prescription (e.g., Rx# and fill date).
- Signature requirements for medications picked up at the pharmacy will also be waived, and signature logs of impacted claims should be documented with the verbiage "Impacted by COVID-19" and initialed by the pharmacy staff.
- Audit teams have been instructed to waive the signature requirement for delivered and picked up prescriptions filled on and after March 1, 2020, with the aforementioned documentation.
CVS Caremark is temporarily allowing pharmacies to use the entry "COVID
" on their signature logs with delivery date and delivery time for retail pharmacy patients that choose not to directly sign. If the pharmacy is delivering the covered item directly to the patient's home, document by writing "COVID Delivery"
when capturing direct signature is not possible. Please maintain the tracking information if you use a common courier rather than one of your employees. As part of documentation, please also include a means to tie the impacted signature captures back to the specific prescriptions (e.g. Rx# and Date of Fill). See the Actual CVScaremark Notice.
American Pharmacies' Recommendation
If you are operating your pharmacy in closed-door mode to limit infection risk, it is challenging to remember and use multiple temporary PBM requirements for signature logs. These requirements will become more cumbersome as more PBMs announce their temporary documentation procedures. To simplify this matter while still providing the needed documentation for PBM and health plans, we recommend you use the following guidelines in lieu of obtaining patient signatures.
- Make sure you maintain separate logs for medications dispensed via your drive-through, those taken to patients waiting at curbside and those provided by home delivery.
- In the signature space, use the entries "CV-19 DT" for drive-through patients, "CV-19 CS" for curbside patients and "CV-19 DEL" for prescriptions that are home-delivered.
- Make sure that the employee who delivers the prescription initials each log entry and enters the Rx number and date for each prescription.
- Make sure you adhere to any special orders or requirements your state may have issued for logging the emergency dispensing of controlled drugs.