Mail Service Pharmacy CSCD 4 - Disclosure

CSCD 4 requires organizations whose payer contracts so provide, to provide upon request to those payers several listed pieces of information.  That information includes information about potential conflicts of interest, discounts, any delegation arrangements, and the pharmacy services pricing structions (e.g., rebates and administration fees).

This general disclosure standard, which carries a tidy sum of 24 points among its component elements, mandates only disclosures to organizations with whom the URAC applicant contracts and provides services, not disclosures to consumers.  

Note that this standard, like nearly all of URAC's standards, requires that you have a P&P that describes the process mandated by the standard.  Make sure the P&P describes who is responsible for assessing whether disclosure is required, when that discosure should be made, how the disclosure is provided, and what the content of the disclosure is. 

Furthermore, this P&P should contain clear organizational definitions of the key terms, such as "conflict of interest."  URAC helps with this by noting that "conflict of interest in this context is a conflict that affects objectivity between the organization’s financial interests and the organization’s obligations to the client."  All terms should be clear, however, not just this important one.

The P&P likely should provide that some of the content will be in the contract with the payer.  For example, the pricing structure should be clearly explained in the contract, including "how it is defined and updated, including the source of the price updates and pricing update time cycle. For example whether drugs are priced using average wholesale price (AWP); how AWP is defined and updated."  

URAC takes a broad view of organizational activities that should be disclosed if they might create a conflict of interest, including not only payment structures for services rendered, but also investments.  

URAC uses this standard to ensure that there is transparency not just about potential conflicts and about payment structures, but also about rebate methodologies and delegation arrangements. 

So, in sum, submit a P&P and a client contract for the desktop review, and make sure the person responsible for the implementation of the P&P is prepped for the onsite review interview he/she is likely to undergo.