Rx Refill Service Fee

Tuesday Nov 19, 2024

Dear Team,

As part of our efforts to improve operational efficiency and maintain high standards of care, a policy change regarding prescription refills will go into effect on January 1, 2025. This new policy aims to balance patient convenience with the need to compensate for the significant time required to process refill requests.

Current Challenges with Prescription Refills

Currently, our policy is to provide enough refills to cover a patient until their next scheduled appointment, plus one additional refill as a safeguard against unforeseen circumstances. However, this approach is not feasible for Schedule II (C2) medications, as federal law prohibits refills on these prescriptions.

Historically, Dr. Herring has provided C2 prescriptions between appointments at no cost to patients. However, the sheer volume of these refill requests has become unsustainable, with Dr. Herring spending over an hour daily managing them. Many other practices require monthly visits for C2 refills to avoid providing uncompensated services. While monthly visits are an option, Dr. Herring recognizes the burden they place on patients and does not consider them mandatory for good clinical care in all cases.

The New Policy

To find a fair compromise between requiring monthly visits and continuing to provide uncompensated services, Tulsa Family Psychiatry & Wellness (TFPW) will begin assessing a $5 monthly processing fee for prescription refills requested between appointments. This policy will apply to all providers at TFPW and under all insurance plans (as well as self pay).

Key Details of the New Policy:

1. C2 Medications (e.g., ADHD Stimulants):
   • C2 prescriptions sent monthly between appointments to prevent clinically unnecessary monthly visits will incur the $5 processing fee.
   • Patients can avoid this fee by scheduling monthly appointments if they prefer.
2. Non-Scheduled Medications:
   • Patients are typically prescribed enough medication to cover them until their next scheduled appointment, plus one additional refill. For example:
     • If a patient is scheduled to return in one month, Dr. Herring will prescribe 30 days of medication with one refill, totaling 60 days of coverage.
   • If a patient runs out of non-C2 medication refills, it is often due to delays in follow-up. In such cases, the $5 processing fee will apply.
3. Exemptions to the Fee:
   • The fee does not apply to prescription changes necessitated by issues such as allergies, adverse reactions, or pharmacy stock problems requiring a substitution after the appointment.
4. Flat Monthly Fee:
   • Patients will only be charged one $5 fee per month, regardless of the number of prescriptions requested. For example:
     • A patient taking both a morning and afternoon stimulant will still incur only one $5 monthly fee, even though two separate prescriptions are issued.

Why This Change?

This adjustment helps ensure we can continue to efficiently manage refill requests without requiring additional office visits for most patients. It also allows us to support operational costs and appropriately compensate providers for the time spent managing these requests.

Staff Expectations

• Consistency Across Providers: This policy applies to all providers at TFPW. Ensure you communicate this consistently to patients who inquire about refill policies.
• Patient Communication: When discussing this policy with patients, emphasize that the $5 fee is intended to save them the time and cost of additional office visits while ensuring they have the medications they need.
• Support for Patients: Encourage patients to schedule follow-up appointments as recommended by their provider to avoid running out of medications and incurring unnecessary fees.

We believe this policy strikes a fair balance between supporting our patients’ needs and maintaining a sustainable practice. If you have any questions or concerns about implementing this policy, please don’t hesitate to reach out.

Thank you for your continued dedication to our patients and for helping TFPW provide exceptional care.

How is this being communicated to patients?

• All Refills and Request Auto-responder updated with link to letter on our website
• Mass SMS to active patients with link to letter on our website
• Mass Email to active patients with letter

Link to letter on our website

Charm Invoicing

This fee can be added to an invoice in a few different ways. These two are the most straight forward:

From: Billing > Invoices > + Invoice

• Description search:
  • Under the Description field, enter terms like, “refill”, “Rx” or “RXSF”
• Choose from Master List:
  • Scroll down to “Non-Covered Services” and locate [RXSF]

Whichever method you choose, it is helpful to enter what medicine or medicines were requested in the “Additional Details” field.

Legal and Regulatory Alignment

Federal law: The $5 Rx refill fee is classified as an administrative convenience fee rather than a medical service. It does not constitute a CPT-billable encounter and therefore falls outside the scope of CMS and commercial insurance billing requirements.

Oklahoma law: The Oklahoma Medical Board (OAC 435:10-7-12) prohibits deceptive billing or charging for unrendered services. However, administrative processing fees are permissible when patients are notified in advance and provide informed consent.

Insurance contracts: Administrative actions such as refill coordination, patient portal processing, and documentation management are not considered reimbursable medical services under standard commercial insurance agreements. Practices may collect reasonable, disclosed administrative fees directly from patients for these non-covered services.

Medicaid carve-out: Medicaid does not allow additional administrative fees beyond contracted reimbursement rates. Accordingly, this fee will not be applied to Medicaid patients.