A Look Back: One Year into OptumRX’s VAWD Requirement

Last month OptumRX demonstrated their continued commitment to their VAWD requirement in a letter delivered to pharmacies. So what has happened over this past year?

A Look Back

1. August 11, 2016: OptumRX announces VAWD Requirement
2. August 11, 2016 to September 30, 2016: An estimated 250 companies rush to apply for VAWD Accreditation.
3. September 23, 2016: NABP launches the VDIP program for diabetic testing supplies.
4. November 4, 2016: Association of Independent Pharmaceutical Wholesalers Inc., based in Pine Brook, N.J., filed its complaint in the U.S. District Court for the District of Columbia.
5. December 1, 2016: OptumRX provides the first extension for their VAWD requirement, good through March 31, 2017.
6. January 2017: NABP transitions from looking into a “Vendor List,” consisting of active vendors to a “Source List,” consisting of all vendor sources for the past three years.
7. February 2017: OptumRX denies its first claim, citing its VAWD requirement.
8. March 21, 2017: OptumRX provides a second extension to applicants for their VAWD requirement, good through June 30, 2017.
9. April 2017 through present: NABP issues a massive wave of cancellations, estimated to be over 50 companies. The companies include heavyweights in the secondary pharmaceutical distribution space, with some doing over $100 million in annual revenue. The cancellations demonstrated a striking shift from NABP’s usual consultative approach to more of a pass/fail approach. Cancellations were in almost all cases predicated on an applicant doing business with an entity that was affiliated with a provider (pharmacy, clinic, hospital, etc.). Cancellations require a 180-day stay. This underscores the importance of having perfected VAWD applications before submitting to NABP.
10. May 1, 2017: NABP confirms that a “Cancelled” application does not equate to a “Denied” application.
11. May 15, 2017: OptumRX requires network pharmacies to complete survey that goes on to become a concrete list consisting of the only vendors from which they are allowed to purchase.
12. June 22, 2017: OptumRX provides a second extension to applicants for their VAWD requirement, good through December 31, 2017.
13. July 2017: OptumRX denies reimbursement claim to a pharmacy purchasing from a VAWD-Accredited distributor that was not included in the Survey submitted by the pharmacy.
14. September 2017: NABP again steps up reporting requirements on purchases and sales stretching from January 2016 to present, including: (1) a report of all intracompany transfers with any affiliated entities; (2) disclosing if any owners or officers are licenses as pharmacists and identify any ownership interests any such individuals may have in a pharmacy; (3) provide a report of all sales to its wholesale distributor customers; and (4) a report of all receipts from specified sources.

Why is OptumRX requiring VAWD?

• “lacked proof of the sale or purchase of the drug products
• the purchase documentation was determined to be altered or illegitimate when validated with the manufacturer
• the pharmacy was unable to demonstrate the chain of custody of the drug products
• the drug product changed hands through as many as seven wholesalers prior to it reaching the pharmacy;
• or, when a pharmacy was audited onsite there were notable concerns with the product packaging that raised potential member health and safety issues.”

Regardless of the reasoning or implementation, it seems that OptumRX will remain committed to its VAWD requirement going into the future.