Kicking off 2025 with another feature-packed release! In this release, we’ll cover some key PBM Compliance features focussed on shipping a prescription to patients in the mail.
Our mission at Alchemy is to ensure that our pharmacies meet patients where they are and this means enabling a robust and compliant mail order delivery program. As discussed before, The number one reason a patient will transfer their prescription to a nearby retail pharmacy location is because they don’t want to drive back to the clinic to pick up their refill (and because another nearby pharmacy exists that is more conveniently located).
Pharmacy Benefit Managers (PBMs) have very specific (and often arbitrary) rules as it pertains to shipping a prescription in the mail. Your PBM contracts may stipulate specific thresholds for mail order (as a percentage of total volume) or even outright prohibit any mail order volume. This requires detailed monitoring to manage a complaint mail order program.
Disclosure: We recommend reviewing your specific PBM contracts to understand the details of your contractual requirements before implementing a mail order program for your in-house pharmacy.
Release #3 Highlights =>
- Shipping Consents
- Signature Logs
- Manual Overrides
PBM compliance is not the same as 340B compliance! As a Covered Entity, you should expect to have a routine PBM audit every 2-3 years across the major Pharmacy Benefit Managers. Similar to a 340B audit, you will be asked to provide dispensation records for a number of patients. The features in this release are designed to ensure that you have all your bases covered during your next PBM audit.
Shipping Consents
As mentioned previously, it is important to understand the mail order thresholds for each of your PBM contractual relationships. Many PBMs will specify specific mail order thresholds (as a percentage of total dispensed volume), while some PBMs will prohibit any and all mail order shipments. Furthermore, PBMs will have different rules and guidelines on how to obtain consent for shipping medications in the mail. As a general rule of thumb, we strongly advise opt-in methods for each and every refill, especially for high value prescriptions. In other words, avoid all “auto-refill” mechanisms where patients elect to have all their future fills mailed to them and instead shift to receiving consent for each and every refill to ensure the highest degree of compliance. PBMs are looking for any sort of reason to slap you with a FWA claim (Fraud, Waste, and ABuse) and a typical trap door is asking patients directly if they consented to receive each refill in the mail and if for any reason the patients said “no, I did not ask for this medication” then the burden of proof falls on the pharmacy to demonstrate intent and consent from the patient to receive that fill, because it is well within the PBM audit scope to ask the pharmacy how they ensured that the patient still needed a particular medication.

Signature Logs
As you ramp mail order and courier deliveries as part of your pharmacy program, it is critical to ensure you have complete signature logs for every medication dispensed. You cannot rely on “Signature on Delivery” methods because (1) this will create an inconvenient experience for patients and (2) very few pharmacies have tools and infrastructure to upload the shipment signature back into their pharmacy management system. When a PBM auditor show up at your doorstep, they will ask for often a random sampling of prescriptions and the pharmacy will be expected to furnish signature logs for all the requested medications, regardless of the dispensation type (in-person, mail order, courier delivery).

Important Note: A PBM auditor is likely not going to ask a pharmacy “Show me the signature logs for these mailed out prescriptions vs. these in-person pickups.” Instead, they are usually asking for signatures logs across the board, and how you manage this process also has an impact on the areas an auditor may focus the rest of their audit. Thus, we match the signature log templates within the pharmacy management system, to ensure a uniform set of signature logs across the board.
Manual Overrides
There will be times when a patient may verbally on the phone (or through another method) consent to and request their refill in the mail. In such scenarios where the patient does not go through the link to share their consent and signature, we allow any pharmacy team member to annotate that they received consent through a different method. This documentation is then stored as part of the signature log, where the timestamp, consent method, and the person requesting the override is all logged as part of a particular refill.
