If a Presidential major disaster or emergency declaration is issued or the Secretary declares a public health emergency, and the underlying circumstances are reasonably expected to result in a disruption in access to covered Part D drugs, CMS expects sponsors to lift their "refill-too-soon" edits. Part D sponsors may exercise some operational discretion as to how these edits are lifted during a disaster or emergency as long as access to Part D drugs is provided at the point-of-sale. For instance, Part D sponsors could implement an edit that is readily resolvable at the point-of-sale through the use of a pharmacist override code. CMS also expects Part D sponsors to allow an affected enrollee to obtain the maximum extended day supply, if requested and available at the time of refill.
Hurricane Sandy is approaching quickly and a lot of questions about what to do to prepare your pharmacies for the storm are being asked. Below are some answers to questions that should help you be prepare.
HIPAA Business Associates or BA’s are persons or companies that are not an employee of the pharmacy but will receive Protected Health Information (PHI) from the pharmacy for specific functions, or activities on behalf of the pharmacy, or services for the pharmacy. These functions or activities could include:
A Disaster Recovery Plan or Contingency Plan is a requirement under the HIPAA Security Rule and the Medicare Quality Standards. Both regulations requires the healthcare provider to plan, safeguard, mitigate, and have a recovery or reconstitution of business plan in place.