The Basics

This standard requires your organization to disclose, upon request, certain information to clients.  Clients are the plans, employers, or insurers who retain your services, not individuals.  The information required to be available in such a disclosure includes:

• Potential conflicts of interest affecting financial or clinical decisions;
• Sources of revenue; and
• The PBM services' price structure, including rebates and administrative fees.

Check with your organization's policies on how, specifically, you will handle such requests, and who will handle them. 

Management Tips

Your P&Ps on this subject should anticipate to who a client is likely to make such a request for disclosure as is covered by this standard.  Also, be clear about what is covered by the conflict of interest component of this standard: any kind of arrangement or structure that affects the organization's objectivity regarding financial interests of the organization and financial and clinical obligations to the client.  This might come up if a manufacturer used a rebate, not shared with the client, to induce the PBM to use one drug over another, less expensive drug.

You should note that the requirement for disclosure of revenue sources applies only to revenue associated with the requesting client.

URAC Accreditation Tips

Each of the four elements of this standard carries a weight of 4.

In addition to the applicable P&Ps, you should submit a client contract template, as this might carry some of the disclosure requirements of this standard.

The onsite review is likely to cover not only a review of actual client contracts, but an inquiry as to whether a client has made such a disclosure request and documentation of how your organization responded to that request.