TIP: Beware of EMR location codes in your data that don’t make sense for prescription generation.
Providers are often in a hurry when they are charting, and sometimes they will open a patient’s chart and choose the most recent encounter to attach a prescription. This can be a common source of error, as the most recent encounter location may not be the location where the provider wrote the prescription. If this location is ineligible for 340B, it could be a red flag during a HRSA audit even if the location was inaccurate.
Regular self-auditing is a vital part of your ongoing 340B program maintenance, and targeted auditing of potentially problematic locations can be an important area of focus. Some examples of problematic locations are lab visits or radiology, where the prescriber may not have seen the patient but the encounter “bubbled up” to the top of the encounter list.
Keep communication open with your providers to stress the importance of choosing the correct encounter when they chart a prescription. If the problem is widespread, contact your TPA and discuss whether blocking problematic locations in your data would be beneficial.
Ryan Doskocil is Technical Training Lead Analyst at Verity Solutions. He can be reached at firstname.lastname@example.org