Compliance services

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Contracts

CalcPartner & ClaimsPartner
Assessment & Audit

COT & PHS Validation

PCX

Features

ClaimsPartner™ – Medicaid Invoicing Made Easy

PharmaComplianceXchange (PCX)

Simplifying the Complex.

Valid Class of Trade (COT) assignment is the foundation to Government Programs compliance as it is the critical first step in establishing accuracy in statutory pricing across the Medicaid, Medicare, VA and PHS programs. Valid Public Health Service (PHS) eligibility is critical to ensuring access to the program by eligible entities, as well as Best Price (BP) integrity in the Medicaid program.

CIS has the right process
Mistakes in COT assignment carry through to all Government pricing calculations. Often, COT assignment has been based on information from GPO lists, inaccurate historical information systems or assumptions based on a customer name; none of which are adequate to address today's Government Pricing regulatory requirements. COT errors are widespread in the industry and can cost your company a great deal, but these mistakes are avoidable.

CIS works with clients to develop the right process and validation procedures to ensure accurate COT assignment for direct and indirect customers who maintain valid PHS eligibility on their PHS contract.

the right solutions
CIS uses efficient tools and processes, as well as methodology assumptions based on current guidance and industry best practices, to provide the assistance and supporting process guidance required to achieve accurate COT assignments and PHS eligibility validation. CIS also evaluates COT schemas and the overall process used to assign COT.

CIS' PHS Validation service includes verifying both historical and current eligibility of PHS entities. If a non-PHS eligible customer improperly receives PHS pricing, your company may be exposed to penalties, fines and restatement requirements if, for example, a new best price is set. In addition, the company will submit inaccurate information to the Government, which may expose the business to a False Claims Act violation. Demonstrating strong processes and a third party review are signs of an effective overall compliance effort.

GP Services	Description
COT DATA VALIDATION	Validates customer COT assignments in customer master files. Validates COT assignment by utilizing a proprietary CIS database and methodology based on industry best practices. Applies COT assignment that is in line with applicable guidance and regulations. The process eliminates duplicate records, evaluates naming conventions and may identify historical customer data issues. The COT validation offering also provides a management report to identify potential GP risks or other compliance issues based on the project findings.
COT SCHEMA AND DOCUMENTATION	Ensures that documentation and COT definitions (schema) are compliant with regulatory requirements and industry best practices, as well as accurate and appropriate for a customer base, contracting strategies, products and GP calculation methodologies.
COT ASSIGNMENT PROCEDURES AND DECISION TREE	Develops and documents a consistent process for the assignment of COT to new direct and indirect customers. Provides policies, procedures and a decision tree related to COT assignment, coordinated with both the commercial and government sides of the business.
PHS ELIGIBILITY REVIEW	Provides validation of PHS eligibility to ensure that both current and past customers are/were eligible to receive PHS pricing for a specific time period. Giving PHS pricing to an ineligible customer may, among other issues, establish an "unexpected" best price.