The Basics

This standard, which has a broader scope than the earlier standards in this module, involves any communication by your organization to either clients or consumers.  It is a specific application of Pharm Core 21 to PBMs, and requires that your organization accurately represent its services and ownership.

This is not just a requirement that you not mislead your clients and consumers.  Rather, it is an affirmative requirement that your organization has implemented mechanisms to ensure that neither employees or agents of the organization are putting out misleading information about the organization.

Such mechanisms might involve training, oversight of oral and written communications, and disciplinary actions taken against persons who mislead consumers or clients.

Management Tips

The burden on management is to document both that you have the mechanisms in place, in the documentary form of P&Ps and training manuals, and that you have implemented appropriate training of employees/agents and oversight over the production of materials.  Documenting the training and oversight will be key, as the reviewer is unlikely to accept only the P&Ps as sufficient evidence of implementation of your mechanisms.  So, make sure your trainings have sign-in sheets which you keep, and that any committee review of documents and web pages is thoroughly documented in meeting minutes.  

URAC Accreditation Tips

Both elements of this standard are mandatory.

For the AccreditNet submission, provide URAC with the communications plan/P&Ps, any relevant training manuals, and samples of client and/or consumer communications materials.

During the onsite review, the URAC reviewer will interview not only your marketing staff members, but also examine evidence of implementation of your protective mechanisms.  This could come in the form of documentation of training sessions, minutes from interdepartmental committees reviewing materials for accuracy, and the materials themselves.