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23.2.1 Creating a transparent Audit Trail
- The treating doctor is expected to supply a list of script and non-script medications necessary for the management of the client's accepted liabilities. A standard letter exists on Defcare that can be used for all clients. These medications need to be recorded on Defcare/Employee Note under a Pharmacy heading so that pharmacy accounts can be matched to the approved list of medications prescribed by the Nominated treating doctor. This is important for two reasons:
- it will identify changes in treating doctors and alert staff to 'doctor and pharmacy shopping' by clients to obtain addictive medications
- it will ensure that pharmacy accounts for medications other than those related to conditions for which liability has been accepted are NOT paid. If in doubt, contact VAPAC for advice.
- Record the request on Defcare. Remember to identify yourself as the author of any information under these headings as this information is altered if someone else enters additional information.
- If required to record specific pharmacy items for approval, include details of the nominated treating doctor/specialist, the exact nature of the medication including dose if that has been supplied, the date, the cost if that is known and the name of the pharmacy who will supply the scripts. This should make sense to anyone looking at Defcare, especially staff trying to pay accounts. Accounts cannot be paid without a record of approval on Defcare. Failure to record approvals means that staff will need to investigate accounts before they can be paid. This is a very time consuming process and unnecessary if approvals or rejections are correctly documented on Defcare and the file.
- If required, create a written approval or acknowledgment letter or fax and forward to the appropriate parties i.e. the requesting practitioner, the pharmacy, the client and the file.
- There will be occasions where non-prescription medication costs will be charged to DVA. The same 'reasonable' test should be applied whether DVA should meet the cost. VAPAC can advise on this.
When requests for medication are denied this is a reviewable decision under S62 of the SRCA. The determination must be in writing to the claimant and must include reasons for the decision as well as a statement that the determination can be reconsidered if the employee or claimant is dissatisfied with the determination. The pharmacy supplying the medication that we are not paying for also need to be advised. If VAPAC has been asked to comment on the case and recommends that treatment be declined their written comments are to be placed on the client's E-file, as well as on their paper file, reflecting that recommendation. A note in Defcare should also be made.
Delegates should be aware that decisions to pay for medical treatment may also be reviewed, albeit not a common occurrence. This may revolve around how much DVA will pay for a service, frequency of service etc. Normal reconsideration practices apply in these circumstances.