Real Time Remote™ Survey Process for Pharmacies

By Lesa Merchant, Vice President DMEPOS/Rx

The Compliance Team (TCT), under authority from CMS, has been conducting virtual surveys due to the Public Health Emergency (PHE). The Compliance Team’s virtual survey process is called Real Time Remote™.

The current PHE declaration is due to expire on April 20, 2021, and we do not yet know whether it will be extended. With that in mind, Real Time Remote (RtR) visits will be on-going. The Compliance Team has been performing RtR visits for almost a year (we started doing them in our Clinic Division in early 2020) and we continue to refine the process. We recently made upgrades to our client portal, which allows for easier document submissions.

The primary difference between the RtR process and a traditional on-site visit is that we use virtual software and phone applications to review your records, policies, processes, and physical environment remotely. However, other than not being physically present in your business, the elements of the visit performed remain the same.

Prior to the virtual portion of the visit, we will email you a list of key documents to upload to our client portal, with a request that these documents be uploaded within 10 business days:

• • The client portal is accessed using the TCT-issued username and password for our website. If you have forgotten or lost your username or password, please contact our home office for assistance.
  • As uploaded documents are received, your account will be moved to our national scheduler, and an accreditation advisor is assigned. The advisor will schedule the RtR visit, factoring in the receipt date of documents, the type of visit, and your accreditation expiration date. Please remember that patient health information and/or confidential employee information is not to be uploaded to the portal.
  • For renewals, we are obligated to conduct a visit prior to your accreditation expiration date, regardless of whether requested documents are uploaded. To ensure a successful visit, it is essential that you be prepared and submit your documents in the outlined time frame.
  • The accreditation advisor assigned to conduct the RtR visit will contact your business 24-48 hours in advance of the remote visit to discuss the application to be used for the remote review and establish a start time for the visit.
  • During the RtR, we will evaluate pharmacy processes and paperwork and review policies and procedures applicable to your pharmacy practices. We will ask to see all pharmacy areas (including refrigerators and freezers) by camera and cover protocols in detail. If you perform immunizations, we will also ask to see where immunizations are performed, the location of your emergency kit and PPE, and all related policies and paperwork.

Over the past year, we have been in contact with many of you and have gained an in depth understanding of how this PHE has created challenges with staffing, patient activities, and daily tasks. As always, we are amazed at the exceptional problem-solving skills our clients possess.

We also remain committed to making sure that our clients are taken care of in a way that minimizes disruption to daily activities and acknowledges the current strain on businesses.

Please contact our home office to make us aware of any specific Covid-19 hardships that affect staff availability or shortages, significant changes to store hours, etc., and we will make note of these issues and do our best to work with your needs.

Thank you for all you do to take care of your patients and each other!