Prescription items are drugs, medicines, medical devices, drinks, regents and appliances, and other such products as may be approved by the Minister of Health.
An owing is a dispensing related activity under the Community Pharmacy Contractor (CPC) Agreement with the HSE, for the provision of services under GMS and Community Drug Schemes. It is a function of a genuine expectation at the time that the claim is submitted, that the patient will return in the near future to collect some, or all, of the remainder of the product that was prescribed in line with Clause 1(1) of the Contractor Agreement. Clause 1(4)(i) of the same document states that “a medicine dispensed and awaiting collection in the pharmacy shall be deemed to have been supplied”.
The owings functionality refers to the management through a pharmacy Patient Medication Record (PMR) system, of an owing within the context of the Community Drug Schemes, and associated reimbursement of the same. The owing functionality implementation within the pharmacy PMR system will allow additional information to be shared with the Primary Care Reimbursement Service (PCRS) through the monthly claim file. This additional information will provide information on the quantities of items dispensed, and quantities owed, against the line-item claim.
Where a partial quantity of a medicine or product is supplied to the patient, only this quantity will be submitted to the PCRS, and the remainder will be identified as an ‘owing’. The electronic claim file submitted to the PCRS for reimbursement will identify any item or any quantity of an item that has not been collected by the patient. This is known as an owing transaction.
Dispensed owing is the subsequent dispensing of the full or partial quantity of an item. This resolves the owing which was previously raised by a pharmacy.
When the patient returns to collect the remainder of the quantity owed, this item is deemed to be supplied. This supplied item is submitted in the electronic claim file to PCRS for reimbursement in the same month that the owing is dispensed. This is known as a discharged owing transaction. The supplied date and time on the item should reflect the actual date and time the item is dispensed. This transaction will have a separate claim number to the original owing transaction.
Standard fees apply in the following way within a calendar month period:
The ‘deferred supply’ fee of €3.27 will be applied for zero supply owing. A ‘top up’ amount to the relevant standard fee will be reimbursed on the first successful Discharged Owing.
This will be paid as and when the item is supplied to the patient and for the quantity supplied.
One of the core functions of the IPU Contract Unit is providing confidential advice and support to members on all contractual matters pertaining to the HSE PCRS. One of the key issues we receive queries on is owings. In this article, we will set out some of the main queries we receive from members on issues concerning owings. We have also included several definition boxes that explain important terms concerning owings. We will first set out the background to developments since 2016 with the PCRS, when owings issues were raised and agreement was sought with the IPU over a final circular to determine this issue.
In May 2016, the PCRS wrote to all pharmacy contractors to clarify their expectation of the claiming procedure for items which were owed to a patient, but which had not yet been supplied and collected by a patient. The letter states: “under Community Schemes, pharmacist should only present a claim for reimbursement by the HSE in respect of items which are supplied on foot of a properly completed prescription in accordance with the Community Pharmacy Contract”. There had to be a “genuine expectation” that the patient would return to collect the item dispensed.
Subsequent circulars were not agreed with the IPU, resulting in a long standoff with the HSE PCRS in reaching agreement. As of 1 July 2020, applicants looking for a new pharmacy contract were required to ensure their pharmacy software provided for transparency of owings claims, i.e., contractors were forced into a position of having to enable the new owings functionality if they wished to obtain a new pharmacy contract. The deferred supply fee was not payable, but following discussions with the IPU in 2022, the payment of a ‘deferred fee’ was agreed to.
This ‘deferred fee’ is equal to €3.27 for every full owing generated without any ingredient being supplied at the initial dispensing/processing. Once the partial or full item is supplied, the dispensing fee balance is rounded up to the dispensing fee due as per the sliding scale (€3.50/4.50/€5.00), and the ingredient cost for the supplied item is reimbursed at this stage.
The IPU and the PCRS also agreed in principle that the owings issue needed to be resolved once and for all. While the IPU agreed in principle with introducing transparency of owings claims in early 2023, we did not agree with the general thrust and implementation plan of the HSE.
In October 2022 an ultimatum was issued by HSE to all contractors about transparency of owings and the wider implementation of the owings functionality: “under contract, pharmacists are obliged to verify the reasonableness and accuracy of claims presented for reimbursement”. HSE PCRS Circular 30/22 explains in detail the PCRS position regarding the circumstances in which it is appropriate to claim for the owed items under the GMS, GMR, Dental and EU Scheme, and those in which claims for owings ought not to be submitted (see hse.ie > Staff and Careers > Primary Care Reimbursement > Circulars for Contractors > Pharmacy Circulars > 2022 Circulars > Pharmacy Circular 30 22 Management of Owings). In this communication the PCRS requested all pharmacy contractors to enable the owings functionality by 31 December 2022.
Since January this year, the IPU has been continuing to engage with the PCRS and the System Vendors to enable the timely rollout of owings transparency software.
As adherence to owings protocol is required, all dispensary staff must be appropriately trained to follow Standard Operating Procedures (SOPs). In circumstances where it is not possible to provide the full quantity of a prescription item, the pharmacy will temporarily owe the patient a balancing quantity and must carry out the following procedure in respect of patients’ safety.
The patient should be advised if an item is owed. Only owings that are necessary and required by the patients should be processed. When a patient has indicated that they are returning for their owed medication, the pharmacist should ensure that the owed product is ordered and will be in stock available for collection as communicated to the patient. An owing label is generated using the PMR for all owed items. The pharmacist should ensure that the patient receives an owing label and is verbally informed regarding the medicine owed. The discharged owing should be generated only when patient returns for collection. When the prescription is marked as an owing, the patient should be informed that the supply was made and that what they are collecting is an owing.
An action plan must be put in place to minimise the level of owings in the future. A review of all recorded owings in the pharmacy electronic dispensing system and the medicines that were not collected is needed on a monthly basis. Patients should be contacted if they have not returned to the pharmacy to collect their medicines within a month of the stock having arrived. The IPU Best Practice Guide to Completing the End of Month (ipu.ie > Pharmacy Contracts > HSE Contracts > Contracts and Claims), can help to keep an owings level to a minimum. However, it is considered that some owings, due to excessively large quantities, bulky or expensive items are unavoidable. An item with an owing on file cannot be dispensed until the owing is supplied to the patient.
Pharmacies during the course of their ‘day to day’ operations may have incidences where the “full amount of medication recorded on a prescription is not available in the pharmacy at the time of supply. This shortage could be filed under ‘owings’ and drawn down when the stock is replenished”. The patient should be at all times supplied with sufficient medication and aware of any supply issues. Patients should be provided with appropriate information and advice on when to return to the pharmacy to collect their full prescription.
For example: A patient presents with a prescription for Atorvastatin 10mg tablets and the quantity prescribed for supply is 28 tablets. However, the pharmacy only has 18 tablets of Atorvastatin 10mg tablets in stock. Therefore, an owing of 10 tablets will be registered for this month. The pharmacy will be reimbursed a standard dispensing fee for the item, and will be reimbursed the ingredient cost based on quantity supplied, which in this case is 18 tablets. When the remaining 10 tablets are supplied, this is the ‘discharged owing’, and the pharmacy will be paid the ingredient cost for 10 tablets and no dispensing fee.
If the supply of the owings takes place within the same day or month, two electronic claims should be submitted for the full payment supply, one for the owing and one for the discharged owing.
Owings can also arise in circumstances where a patient decides not to collect all of the medicines on a particular prescription at the one time. In circumstances where the patient does not require all their prescribed medication, the pharmacist should establish the reason why, and review the patient’s health needs as appropriate. Pharmacists may need to exercise their professional judgment and may decide to refer the patient back to the GP when they deem it necessary. Only when the pharmacist is satisfied that the patient will return to collect their medicine should they register it as an owing. An item that is not required should not be filed under ‘owings’ where there is no supply. In this particular situation, the prescription may be kept open for a limited period, and to ensure that all owings are dealt with in an efficient manner, it will be of vital importance to establish if the patient will return within the calendar month to collect a full prescription:
In accordance with the CPC Agreement, pharmacists should only present a claim for reimbursement in respect of products which are supplied on foot of a valid prescription. The HSE acknowledges that the vast majority of pharmacy claims are reasonable, valid and in compliance with contractual agreements in place.
In any situation where owings arise, and the pharmacy contractor has otherwise carried out their contractual dispensing obligations in relation to the medicine that is not collected, they will be paid as agreed.
Contractors should manage their owings appropriately to ensure that invalid claims are not submitted to the PCRS which are misrepresented as supplied to patients. Any claiming for products not actually supplied to the patient on the recorded date of dispensing, or prepared and awaiting collection where there is not a genuine expectation that the patient will collect the product, are considered not appropriate claims, and should not be claimed as owings.
The introduction of owings transparency software was agreed to by the IPU. It is important that in all our future interactions with State Bodies such as the Department of Health, that community pharmacies are viewed as fully compliant with our fiduciary duties to the taxpayer and general population.
Zrinka Bulj
Claims Analyst, IPU
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