Mail Service Pharmacy CSCD 1 - Post-Enrollment Consumer Information Requirements

This mammoth, 80-point standard sets forth detailed requirements for your organization on information you have available for consumers on a variety of issues.  That information includes:

• financial information (consumers' financial responsibilities and tips)
• information regarding access to pharmacy services (e.g., product selection, refill exceptions, instructions on getting help, placing orders, handling delays, dealing with emergencies, getting an order status, finding a pharmacist, finding a consumer advocate, drug substitutions, switching facilities or PBMs)
• health and safety information (rights and responsibilities, evidence-based information about common ailments, handling drug recalls, safe disposal of drugs, handling adverse drug reactions, drug substitutions,
  etc.)

This is an enormously important standard, if for no other reason than the sheer number of elements and, therefore, points -- 80!  

First of all, however, note that this huge standard may not even apply to your organization.  It may be that your client has not delegated this function to you, and retains it for itself.  If that is the case, simply submit an attestation to that effect, with an explanatory note to accompany that attestation that makes it clear that this standard is not applicable to you.

If the standard does apply to your organization, however, the good news is that it is a rather straightforward list of pieces of information that the organization must provide to the consumer upon enrollment.  That information is in three categories: financial, pharmacy access, and health/safety.  So, if you simply go through your post-enrollment consumer disclosure documents, point by point, and make sure that it meets each of these elements, you can pick up a pretty easy 80 points toward your full accreditation.

What is that documentation?  URAC says it is not prescriptive about methods (e.g., paper vs. electronic), but don't be fooled -- you need to make sure that, whatever disclosure method(s) you use, your information gets to all of your consumers.  So, if you have folks who don't have access to the Internet, you'd best not rely solely on Web-based disclosure.  The documents that URAC suggests as possibilities for submission give you an idea of all the many ways URAC can envision your organization gives this information to consumers:

• Policies and Procedures
• Pharmacy directory
• Website
• Employee training material
• Correspondence to consumers
• Generic Consumer Education Policies and Procedures
• Communication Plan

The "Interpretive Information" and "Points to Remember" for this standard are particularly instructive.  I won't reproduce them here, but I recommend that you review each paragraph in this information-rich section.  They will provide far more information about the documentation for each of the 19 elements of this standard than the "Evidence for Desktop Review."

The video, below, fleshes out this advice with some tips on how to think about this standard and make sure your organization complies with it.