PBMs recognize home delivery can provide an alternative way of safely accessing prescribed medications. To promote expanded access to home delivery, PBMs are temporarily waiving requirements for pharmacies to obtain proof-of-receipt signatures from patients, unless required by law.

Because of the high transmission risk posed by the novel coronavirus (COVID-19), proof-of-receipt requirements may represent an unintentional pathway for pharmacy professionals, patients, and mail carriers alike. PCMA recommends states, including their Boards of Pharmacy or Medicaid agencies, as appropriate, temporarily waive proof-of-receipt/delivery requirements and instead consider:

• Permitting the practice adopted by several PBMs and health plans of allowing pharmacists to write “COVID-19” in the signature box; or

• Mirroring New York’s Medicaid Pharmacy Guidance that allows pharmacies to confirm delivery through phone call, text, or email, in lieu of a signature.

PCMA also recommends the Centers for Medicare & Medicaid Services issue guidance to states clarifying that they may temporarily relax signature log and similar requirements (relating to delivery) without program integrity or audit repercussions. While not expressly required under federal Medicaid regulations, many states’ Medicaid signature requirements were established in response to program integrity concerns and to demonstrate services billable to Medicaid were delivered.

To find out more on what PBMs are doing, click here.