Pharmacy Cost Management
Multi-stakeholder benefits decisions where employer groups, brokers, and members must align on coverage and cost.
Inside this journey
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Pre-Discovery
Align stakeholders, required disclosures, and data permissions before deep technical analysis.
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Stakeholder Alignment
Confirm CFO, Director of Benefits, procurement, and advisory roles, timelines (18+ months before renewal), and decision criteria.
Alignment Questions
Quick hello: who are we speaking with today?
- Which of these best describes your role for pharmacy benefit decisions?
- How many covered lives does this plan represent today?
- When does your current PBM contract expire (month/year)?
- Who recommended or helped select your current PBM?
- If there’s one thing you want us to know about your situation before we dig in, what is it?
Are you okay letting a three-year PBM contract quietly cost you millions?
- How confident are you that your current PBM reports capture all rebate retention and spread accurately?
- Tell us about the last time pharmacy costs surprised you—what happened and how did it feel to the finance team?
- Have you seen NDC-level claims and pricing detail for the period driving the renewal increase?
- Which internal teams get pulled into investigating a pharmacy spike? (select all that apply)
- How does the leadership team react emotionally when a renewal projects double-digit increases—panic, pressure to act quickly, or cautious analysis?
Show us exactly where you think money might be leaking
- Do you have line‑level visibility into rebate schedules, aggregation methods, and pass‑through terms today?
- Which of these contract primitives do you believe are most likely to be costing you money right now?
- Do you have access to PBM claim line fields we’d need for an NDC-level audit (NDC, ingredient cost, dispensing fee, NABP, prescriber, date of service)?
- If you had to estimate, what dollar range of potential overpayment would make you pursue a full audit?
- Describe any past findings from audits or vendor reviews—what did you find, who reacted, and what changed?
If we could show you NDC‑level proof of millions saved, what would you actually do with it?
- What minimum level of projected annual savings would justify a vendor change or aggressive renegotiation for your team?
- Would dollar-level NDC evidence need CFO sign‑off, board approval, or is benefits/procurement empowered to act?
- If savings are primarily from therapeutic substitution or 340B optimization, how open is clinical leadership to implementing those changes?
- How specific must our recommendations be for you to accept them (e.g., product-level NDC swap with projected $ per member per year vs. high-level categories)?
- Imagine the audit shows issues with rebate pass‑through—what outcome would you consider a success (recover funds, renegotiate, terminate)?
Who really signs the check and who will push back?
- List the decision‑makers who must approve a PBM retainer or contract change and their typical priorities (finance, clinical, procurement, executive):
- Are there external advisors or brokers who must be consulted before decisions—and do they have financial ties to PBMs?
- How important is a signed independence disclosure from your advisor when selecting an auditor?
- What internal approval hurdles have delayed past vendor changes or contract renegotiations?
- Who will be the day‑to‑day owner for data collection, questions, and signoffs during an audit?
If the PBM digs in and limits data, what will you do differently?
- Have you experienced PBM resistance to sharing detailed claims or rebate files in the past?
- What format do your available files arrive in today (select all that apply)?
- Which internal systems or teams will need to be involved to map and ingest PBM data (HRIS, Data Warehouse, IT security)?
- Do you have legal or contractual constraints that limit sharing NDC‑level claims externally?
- Describe any previous attempts to reconcile rebates, MAC, or spread issues—what data was missing and who owned the follow‑up?
How will you judge whether our audit is credible and defensible?
- Which teams must sign off on our final acceptance checklist (Finance, Clinical, Legal, Procurement)?
- Do you require an independent reconciliation of rebates and savings (e.g., finance-run reconciliation) before changes are implemented?
- What sample size or time window would satisfy you that findings are valid (e.g., 12 months of claims, rolling 36 months)?
- Which KPIs will determine success after deployment (dollars saved, PMPM reduction, rebate capture %, formulary compliance)?
- Who will be the primary contact for disputed contract interpretations if we surface a compliance gap?
What keeps you awake at night about doing this audit?
- Which of the following political or operational risks worry you most if audit findings require renegotiation?
- How tolerant is your leadership for public confrontation with an incumbent vendor versus quietly negotiating fixes?
- If a findings report triggers a formal dispute, who leads the response and what timeline would you expect?
- Share a specific internal political hurdle you’ve faced on benefits projects—what happened and how was it resolved?
If we commit to a short pilot, what would make us an easy yes?
- How soon would you be willing to provide test claims data for a pilot analysis (assuming NDAs and security controls are in place)?
- What budget or retainer range are you comfortable allocating to independent PBM audit and renewal support?
- Which SLA elements matter most for you during the renewal window (data turnaround time, findings cadence, dispute response time)?
- What would be an acceptable timeline from pilot to a board‑ready findings report?
- If we ask for a signed independence disclosure and data access authorization, who in your organization needs to sign?
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Independence & Conflict Disclosure
Obtain signed disclosures confirming zero financial relationships with PBMs, manufacturers, or specialty pharmacies.
Disclosure Checks
Starting the Conversation: Where are you right now?
- Tell us the size of the self-funded population you're responsible for (covered lives).
- When does your current PBM contract expire (or next renewal window)?
- Briefly describe the immediate trigger for this review (e.g., renewal increase, specialty spend spike, consultant recommendation).
- What percentage increase did your pharmacy spend show in the most recent renewal notice (approx)?
- Who will be the primary day-to-day contact for this discovery (name/role)?
- Who are the core decision-makers for PBM renewal (select all that apply)?
Are You Being Told the Whole Story?
- What would it mean to your organization if the PBM's reporting omitted millions in retained rebates or spread?
- Which of the following have you seen in your PBM reports that feel incomplete or unclear?
- Have you requested NDC-level rebate and pricing detail from your PBM before? If yes, what happened?
- How confident are you that the PBM’s claims reporting can be reconciled to your finance systems at the dollar level?
- Describe a specific example when PBM reporting left you frustrated or forced a difficult decision.
- Who on your team currently validates PBM reports and how do they escalate concerns?
Who’s Steering the Ship — and Who Might Have Conflicted Ties?
- If one of your advisors has a referral relationship with the PBM, how would that change your trust in their recommendations?
- Which external advisors are currently involved in your PBM strategy or renewal? (select all that apply)
- Do you have signed disclosure statements confirming advisors' financial relationships with PBMs, manufacturers, or specialty pharmacies?
- Who on your side would need to sign an independence/zero-relationship disclosure from an advisor or vendor?
- How would you feel if a recommended advisor refused to sign a disclosure stating zero financial ties to PBMs?
- Tell us about any past situations where vendor or advisor conflicts affected outcomes (what happened, and what did you learn?).
What Does ‘Meaningful Savings’ Look Like for You?
- Would a category-level savings estimate be sufficient for your CFO, or does the savings case need NDC-level, dollar-specific line items?
- What minimum annual savings (net of fees) would justify a change or aggressive negotiation with your PBM?
- Which of these NDC-level opportunities would your team consider actioning if proven (select all that apply)?
- How important is clinical team buy-in (pharmacy medical director, PBM pharmacist, or internal clinicians) to approving NDC-level recommendations?
- What level of confidence do you require on projected savings (e.g., 90% certain, range, or conservative estimate)?
- Share an example of a savings claim from a vendor or advisor that felt overpromised—what was missing?
Data & Access: If You Can’t Get the Files, Nothing Else Matters
- If the PBM resists providing full NDC-level claims and rebate detail, what are you willing to do to secure it?
- Which of these datasets can you already share quickly (select all that apply)?
- How long will it realistically take to obtain necessary legal approvals (DUA, BAAs, counsel sign-off) to share NDC-level data?
- Have you experienced PBM delays or pushback on providing data in the past? Describe the impediment.
- Would you be open to a phased data approach (sample months or a de-identified subset) to validate capability before full ingestion?
- Which internal owner will be responsible for shepherding data requests with the PBM?
When Findings Force Hard Conversations, Are You Ready?
- If an audit shows your PBM missed guarantees or retained rebates improperly, how willing are you to escalate to contract renegotiation or termination?
- Who would lead the governance and dispute process (roles and escalation path)?
- Do you have budget or executive support for an advisory retainer to cover detailed NDC-level audit work during the renewal window?
- Which outcomes would justify paying an advisory retainer (select all that apply)?
- If a dispute arises, how important is having an independent, signed disclosure of advisor independence to support your position?
- Describe the most important non-financial outcome you’d need from an audit (e.g., transparency, vendor accountability, policy change).
What Would Full Transparency and Success Enable?
- Imagine you finish renewal with NDC-level clarity and confirmed rebate pass-through—what decisions become possible that weren’t before?
- Which KPIs would you use to judge this engagement’s success at 6 and 12 months (select all that apply)?
- How quickly do you need initial audit findings to inform negotiation strategy (timeline)?
- What reporting format will finance and clinical teams require to sign off on recommendations (NDC-level spreadsheets, executive summary, reconciliation worksheets)?
- If we identified actionable savings, what internal approvals are required to implement changes (roles and signoff thresholds)?
Next Steps: How Do You Want Us to Partner?
- Would you prefer we start with a short proof-of-value (sample months) or a full NDC-level ingestion up front?
- What level of interaction do you want during discovery (weekly checkpoints, biweekly updates, as-needed)
- Who needs to be included in our next meeting (roles and names)?
- What would make you comfortable signing an independence disclosure from us (elements or assurances we should include)?
- Realistically, when could you commit to providing a sample dataset or approvals to begin work?
- Is there anything else we haven’t asked that would change how you approach a PBM audit or vendor selection right now?
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Data & Access Authorization
Secure PBM claims exports, encounter files, rebate schedules, MAC logs, and required legal permissions for NDC-level analysis.
Data Authorization
Getting Comfortable Together
- Who are you and which roles will you personally represent in the pharmacy renewal process?
- When does the incumbent PBM contract expire (or when is your renewal window starting)?
- How many covered lives does this plan include today?
- How has total pharmacy spend changed over the last 12 months (approx.)?
- What are your immediate feelings about the upcoming renewal—confident, anxious, resigned, curious, or something else?
- Who on your team will be the day-to-day contact for data and scheduling?
If Your PBM Numbers Are Wrong, How Fast Would You Feel the Pain?
- If your PBM's reporting understated overpayments by 20% next year, what would that mean to your budget or renewal strategy?
- Which part of PBM reporting makes you most suspicious: rebate pass-through, spread pricing, MAC compliance, or rebate allocation?
- Have you ever commissioned an independent NDC-level audit before? If yes, what did you find and how was it handled?
- How comfortable are finance and clinical leaders with the level of detail in current PBM reporting (NDC-level vs. category-level)?
- What specific story or evidence would convince you that a PBM is retaining plan money rather than passing it through?
- Who on your side would need to approve running a historical claims sample through an independent platform?
Where the Money Might Be Hiding
- How certain are you that rebates and spread are being passed through at competitive rates?
- Which therapeutic areas or drugs are driving the recent spike in costs for you?
- Estimate the dollar range you believe could be at risk from poor pass-through or spread over a three-year contract.
- Have you observed unexplained variances between PBM rebate schedules and actual remittances to the plan (e.g., timing, aggregation differences)?
- How would discovering material overpayment change your approach to advisor relationships or procurement strategy?
- Which outcomes would you prioritize if we found leakage—recover dollars, renegotiate contract terms, change PBM, or public disclosure?
The Truth About Your Data
- If we asked the PBM for NDC-level claims exports, encounter files, rebate schedules, and MAC logs tomorrow, what would they likely provide?
- Which of the following data items do you already have or can compel for analysis?
- What file formats and transfer methods are available from your vendors (select all that apply)?
- Do you have signed legal permissions and data-use agreements in place to allow an independent audit of identifiable claims at the NDC level?
- Who owns the data handoff internally (name/role), and how quickly can they onboard secure access?
- What privacy or security constraints would we need to honor (PHI redaction, SOC2 vendor requirements, encrypted SFTP, etc.)?
- Have you previously requested MAC logs or rebate detail from the PBM, and if so, what was the response?
Who Needs to Be in the Room — Really
- If you could pick the three people whose buy-in matters most for a successful audit and recovery, who would they be and why?
- Which of the following stakeholders will influence the renewal decision and must sign off on findings?
- Do you have an advisor or consultant with a referral/financial relationship to the incumbent PBM that we should be aware of?
- Who on your team typically approves retainers or advisory spend for renewal work (role/title)?
- What internal approval hurdles or procurement rules could delay starting an audit (e.g., RFP required, legal review cycles)?
- How does knowledge of a benefits consultant’s PBM tie-in change your willingness to act on audit findings?
What Success Actually Looks Like (Dollar-level, Not Buzzwords)
- What is the minimum dollar impact that would make an audit and potential renegotiation worthwhile to you?
- Which acceptance criteria would your finance team require to sign off on audit results?
- Over what timeframe would you expect recovered or avoided spend to be realized (select all that apply)?
- Would you consider a pilot focused on a high-risk NDC cohort before a full audit? If so, which cohort would you prefer?
- Which commercial models would you find acceptable for advisory/tech work (select all that apply)?
- Who must endorse the final acceptance (e.g., CFO sign-off, clinical lead sign-off, procurement approval)?
Barriers, Politics, and the Quiet Resistance
- Who inside or outside your organization could quietly block or slow a PBM audit if results threaten trusted relationships?
- Have you experienced pushback from your PBM when asking for granular data or reconciliation in the past?
- If the PBM disputes an audit finding, how would you prefer to handle it: mediation, escalation to counsel, leverage benchmarking, or publicly disclose?
- Would internal politics make it harder to recover funds even if we proved overpayment?
- What communications or governance structures would make leadership more comfortable with audit findings being acted upon?
- Have you defined a dispute governance process for contested contract interpretations today?
Next Steps That Don't Waste Time
- If we could surface a credible NDC-level problem within 30 days, what would you want us to deliver first (evidence packet, executive brief, financial model, or remediation roadmap)?
- How soon could you provide an initial data sample (e.g., 3–6 months of claims) for a fast proof-of-value?
- Which short checklist items must be completed before legal will approve an external audit (BAA, DUA, vendor security review, procurement PO)?
- What's your preferred cadence for check-ins during discovery and pilot phases?
- Who would be responsible for internal stakeholder briefings when we present preliminary findings?
- Are you ready to proceed with a scoped pilot if we agree on access and commercial terms today?
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Customer Discovery
Document target savings thresholds, NDC-level acceptance criteria, current PBM reporting gaps, and internal approval constraints.
Discovery Questions
A Quick Start — Why We're Here Today
- Which of these best describes what's prompting you to evaluate PBM performance now?
- In one sentence, what is the single most important outcome your CFO is hoping this review will deliver?
- Who will be the primary day-to-day owner for providing data and answering follow-up questions?
- How confident are you today that your existing PBM reporting gives you the detail you need to evaluate true pass-through and spread?
What Are You Really Worried About?
- If you had to guess today, where is the majority of your pharmacy overspend hiding — rebates withheld, spread pricing, MAC errors, specialty site-of-care markup, or something else?
- Tell us about a recent moment when PBM reporting left you frustrated — what did you read in the report and what didn't make sense?
- How does uncertainty about pharmacy spend show up operationally or emotionally for your finance team and leadership?
- How long have you been tolerating that uncertainty before deciding to act?
- What would be the reputational or budgetary impact if a contract renewal locked in hidden fees or unfavorable guarantees for the next three years?
The Dollars That Keep You Up at Night
- What minimum annual savings or recovery number would make this engagement an unqualified success for your CFO?
- Do you evaluate savings targets at the plan-level only, or do you require NDC-level (per drug/NDC) quantification before approving recommendations?
- What dollar tolerance would your finance team accept for estimation variance on projected savings (e.g., ±$X)?
- Describe a past example (if any) where a vendor’s projected savings didn’t materialize—what went wrong and how was it discovered?
- Which stakeholders would need detailed dollar-level briefings before they would sign off on any contractual changes?
How Deep Do You Want Us to Look? (NDC-Level Expectations)
- Which NDC-level acceptance criteria matter most when approving identified savings (select top priorities)?
- What maximum per-prescription variance (price difference) would you accept for an NDC to still be considered compliant?
- Do you require clinical team sign-off (pharmacy director or medical director) on every NDC-level recommendation before implementation?
- How granular does benchmarking need to be to convince you — national averages, peer employers of similar size/industry, regional, or custom matched peers?
- If we propose therapeutic substitution or site-of-care shifts, what clinical guardrails or approval steps must be in place?
The Data Gate — What You Can (and Can’t) Share
- Which of the following data files can you provide for a NDC-level audit within the next 30–60 days?
- If any of the critical files are unavailable, which are hardest to obtain and why?
- Do you have existing legal/dataroom permissions or NDAs that would allow us to ingest PBM exports and execute NDC-level analysis?
- How have PBMs historically responded to data requests from your team—collaborative, delayed, or obstructive?
- Who in your organization will be the data gatekeeper and what typical hurdles (IT security, vendor contracts, procurement) should we expect?
Decision Dynamics — Who Moves the Needle?
- If a material overpayment is uncovered, who has the authority to negotiate the PBM contract or approve legal action?
- What internal approval milestones or committees must sign off before money can be recovered or contract language changed?
- When you describe internal resistance to pushing back on a PBM, what does that resistance look and sound like (political, relationship with broker, fear of disruption)?
- How much advance notice (months) does procurement/finance require before a renewal negotiation to feel prepared?
- Are there external constraints (union contracts, single-source bargaining agreements, regulatory limits) that would limit negotiation options?
Reporting Gaps — What Your Teams Keep Asking For
- Which reporting gaps cause the most friction between finance and benefits teams today?
- Describe a report or metric you’ve requested from the PBM that never arrives in the format or detail you need.
- How often do finance and clinical teams disagree on the acceptability of PBM-reported savings or compliance metrics?
- Would a standardized NDC-level dashboard with drill-downs into rebate allocations, MAC changes, and adjudication exceptions change decision-making cadence? If so, how?
- Which formats do your teams prefer for validated findings — slide decks, CSVs with reconciliation, interactive dashboards, or formal audit reports?
What Would Success Feel Like—Down to the Dollar
- If we delivered a validated NDC-level audit and you presented it to your CFO, what three metrics would the CFO ask about first?
- Beyond recovered dollars, what non-financial outcomes would signal success (e.g., improved contract transparency, stronger vendor accountability, reduced internal friction)?
- How quickly would you want tangible deliverables (sample NDC findings, reconciliation workbook) after we receive data?
- Would you prefer staged deliverables (quick wins first, then deep-dive) or a single comprehensive report? Why?
- What level of external attestation or legal defensibility do you need if findings are challenged by the PBM?
Decision Tradeoffs You're Willing to Make
- If pursuing maximum recovery requires a longer procurement timeline or legal escalation, how willing is leadership to accept those tradeoffs?
- Would you accept a phased commercial model (retainer + success fee tied to recoveries), or does procurement require a fixed-fee engagement?
- How important is vendor independence (no PBM/manufacturer relationships) in your evaluation—deal breaker, strong preference, or nice-to-have?
- Would you be open to a pilot on a subset of claims (e.g., highest-cost specialty drugs) to validate approach before full engagement?
- If we identify recoverable amounts, what recovery methods are acceptable: contract negotiation credit, cash recovery, or future rebate adjustments?
Practical Next Steps & Timelines
- Assuming we agree to proceed, what is your ideal date to have initial NDC-level findings in hand?
- What approvals must be completed before data can be shared (legal, procurement, IT security), and how long do those approvals typically take?
- Who should be included in kickoff and progress meetings (list names/roles), and how often do you prefer status updates?
- What would make you stop a pilot or engagement early (e.g., lack of access to key files, unacceptable false-positive rate, governance roadblocks)?
- Finally, what is one concern you hope we explicitly address during discovery that would make you feel this project is worth your team's time?
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Solution Experience
Run representative historical claims through the platform and walkthrough NDC-level findings, rebate pass-through assessment, and contract compliance implications.
Experience Meetings
- Solution Experience — Prep & Current-State Confirmation
- Claims Ingestion & Mapping Sanity Check
- NDC-Level Findings Walkthrough — Diagnosis → Proof → Validation
- Rebate Pass-Through & Contract Compliance Implications
- Executive Snapshot & Next‑Step Decision Alignment
- Decide whether findings will be pursued immediately or included in renewal negotiations.
- Stakeholders validate that the presented NDC examples reflect the stated current-state problems.
- Agree on a defensible dollar estimate of recoverable or preventable cost tied to the sample.
- Identify the top NDCs to prioritize for immediate remediation or PBM dispute.
- Collect any clarifying inputs required to formalize the findings report.
- Platform to produce a formal NDC Findings Report (including drill-down screenshots and dollar impact) within 3 business days.
- Customer to confirm clinical/quality acceptance criteria for any substitution recommendations.
- Assign owners for each priority NDC to lead PBM follow-up or internal formulary change.
- Rebate Pass-Through Methodology
- Agree on a defensible rebate shortfall figure and the contract clauses that support escalation.
- Establish a clear dispute governance process with owners and timelines.
- Introductions & Objectives
- Platform to deliver a rebate reconciliation workbook reconciled to customer finance fields.
- Customer legal/finance to review and mark contract clauses for formal dispute or negotiation.
- If pursuing dispute: draft and approve the initial data request/notice to PBM within agreed SLA.
- Executive One-sentence Recap
- Executive sign-off to proceed to the next commercial step (retainer or remediation) or to specify alternative actions.
- Agree on which acceptance criteria from the Solution Experience have been met.
- Establish immediate milestones, owners, and the date for Deployment Readiness planning.
- Customer to communicate decision and, if approved, sign the advisory retainer or pilot statement of work.
- Platform to deliver the executive one-page report and a proposed SOW with milestones and fees.
- Schedule Pre-Deployment Readiness meeting and assign owners for data SLAs and ingestion responsibilities.
- Achieve a single agreed sentence that crisply states the current state.
- Agree on a quantified consequence (dollar estimate or range) tied to the current state.
- Define clear, measurable success criteria and the future-state sentence that the experience must prove.
- Confirm all data required for the run has been received or has a delivery date.
- Customer to deliver the representative claims extract and PBM contract excerpts (if not already shared).
- Customer to provide the one-sentence current state and an estimated dollar consequence for prioritization.
- Platform team to validate file formats and confirm mapping assumptions within 48 hours.
- Schedule Claims Ingestion & Mapping Sanity Check meeting with technical leads.
- Ingestion Overview & Live Pipeline Run
- Complete a successful ingestion of the representative sample with documented mapping results.
- Identify and prioritize data issues that would materially affect NDC-level findings.
- Agree which issues require immediate remediation vs. caveated presentation.
- Platform team to provide a detailed ingestion report listing mapping exceptions and suggested fixes.
- Customer IT/PBM liaison to supply any missing files (rebate schedules, MAC logs, encounter detail) within the agreed SLA.
- Agree date for the primary NDC-Level Findings Walkthrough after remediation items are addressed.
- Recap Current State & Consequence (1-sentence + $)
- NDC Mapping Validation
- Top 5 NDC Discrepancies — Live Drill-downs
- Summary of Quantified Findings
- Findings: Rebate Shortfalls & Dollar Impact
- One-sentence Current State
- Therapeutic Substitution & Biosimilar Opportunities
- Consequence Quantification
- Recommended Next Actions & Commercial Options
- Rebate & Encounter File Linkage
- Contract Clause Mapping & Ambiguities
- Acceptance Criteria & Decision
- Contract Guarantee & MAC Breach Examples
- Define Future State & Success Criteria
- Dispute Playbook & Governance
- Anomaly Detection & Data Gaps
- Confirm Milestones & Owners
- Sign-off Criteria for Main Walkthrough
- Validation Checkpoints
- Data & Logistics Check
- Decision Points & Next Steps
- Risks & Communication Plan
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Solution Scope
Define modules (claims ingestion, contract configuration, NDC audit depth, benchmarking, continuous monitoring) and measurable deliverables.
Scope Configuration
- Ingest and Normalize Pharmacy Claims Data
- Map PBM Contract Guarantees into Platform
- NDC-Level Claims Reconciliation and Price Validation
- Invoice Line-Item Rebate Pass-Through Validation
- MAC Pricing Compliance Reconciliation
- Automated Claims Validation and Recovery Filings
- Deploy Therapeutic Substitution Interventions
- Implement Biosimilar Conversion Workflows
- Execute Specialty Site-of-Care Redirects
- Perform 340B Carve-In Recovery Transactions
- Deploy Pricing Benchmark Dashboard
- Activate Real-Time Contract Compliance Alerts
- Produce NDC-Level Dollar Savings Scenarios
Scope Questions
Ingest and Normalize Pharmacy Claims Data
- Do you have historical pharmacy claims exports available for ingestion?
- What file formats can your PBM provide for claims and encounters?
- How many months of historical claims do you want ingested for baseline analysis?
- Do your files include NDC-level line items, unit quantity, unit price, and paid amount?
- Are member identifiers, plan IDs, and encounter/payment linkage fields consistently populated?
- Describe any known data quality issues (e.g., truncated fields, multiple separators, mismatched dates).
Map PBM Contract Guarantees into Platform
- Do you have a signed PBM contract and any amendments available for configuration?
- Which guarantee types in the contract need to be modeled?
- Are guarantees defined at NDC, GPI, or therapeutic category level in the contract?
- Is there historical invoice documentation we can use to validate configured guarantees?
- Are there contract clauses requiring aggregated or blended reporting that impact how guarantees are interpreted?
- List any known dispute timelines (e.g., appeal windows) or special interpretation rules to encode.
NDC-Level Claims Reconciliation and Price Validation
- Do you require reconciliation at the NDC level for every claim line or for high-cost categories only?
- What threshold should trigger an NDC-level deep-dive (e.g., $ per claim, % of monthly spend)?
- Do you want automated flagging for price anomalies vs. benchmarks (Yes/No)?
- Are there external price reference sources (AWP, NADAC, WRX) you prefer for validation?
- Should reconciliations include dispensed quantity validation (days supply vs. units dispensed)?
- Describe any required outputs for finance and clinical teams (e.g., reconciliation ledger, claim-level exceptions CSV).
Invoice Line-Item Rebate Pass-Through Validation
- Do your PBM invoices include line-item rebate pass-through detail or only aggregate rebate credits?
- Do you want reconciliation of contracted rebate %s and actual remitted dollars at the NDC or manufacturer level?
- Are manufacturer rebate schedules and effective dates available for mapping?
- Should pass-through validation include retrospective true-up calculations and timing windows?
- What acceptance criteria should be used to escalate a rebate discrepancy to the governance team (e.g., $ threshold, % of expected)?
- Provide any invoice examples or redacted samples that show rebate line structure.
MAC Pricing Compliance Reconciliation
- Does your contract include MAC lists or guarantees tied to specific MAC tables?
- Do we have access to PBM MAC change logs (timestamps, effective dates, reason codes)?
- Should the system verify MAC enforcement windows and appeal deadlines?
- Do you want retroactive identification of MAC violations and estimated recoveries?
- Which formularies or plan designs (e.g., tiers, exclusions) affect MAC application that we should map?
- Describe required MAC compliance deliverables (e.g., violation log, recovery claim files).
Automated Claims Validation and Recovery Filings
- Do you want automated generation of recovery filing packages for the PBM (claim extracts, justification docs)?
- Should the platform create appeal timelines and owner assignments for each recovery item?
- Do you have a legal or procurement process that dictates recovery communications templates?
- What recovery success metrics matter (dollar recovered, time to close, % upheld)?
- Do you require automated posting to your finance system for expected recoveries?
- Specify any regulatory or compliance constraints on recovery outreach (e.g., vendor communication policies).
Deploy Therapeutic Substitution Interventions
- Are therapeutic substitution opportunities allowed in your plan and by your PBM contract?
- Which clinical stakeholders must approve therapeutic substitution recommendations?
- Do you want actionable intervention lists (member-level outreach, prescriber letters, prior auth changes)?
- What acceptance criteria for substitutions (therapeutic equivalence, cost delta, clinical overrides)?
- Should interventions include estimated dollar impact and implementation effort?
- Describe any plan restrictions (carrier mandates, union rules, clinical exclusions) affecting substitution.
Implement Biosimilar Conversion Workflows
- Do you have high-cost biologic medications in your population targeted for biosimilar conversion?
- Do you require provider-level outreach and prior authorization workflow changes for conversions?
- Should the workflow manage interchangeability rules, medically necessary exceptions, and patient consent logging?
- What savings acceptance threshold should trigger conversion outreach (e.g., $ per member per year, % of spend)?
- Do you require tracking of conversion rates and downstream adherence/clinical outcomes?
- Provide any payer or provider constraints (e.g., specialty pharmacy limits) that affect biosimilar execution.
Execute Specialty Site-of-Care Redirects
- Do you have spend concentrated in specialty infusion, physician-administered, or outpatient clinic settings?
- Are site-of-care redirection opportunities permitted under current contracts and clinical requirements?
- Should the project include vendor or network sourcing to enable redirection (e.g., infusion centers)?
- Do you want patient-level impact analysis (travel, co-pay changes, clinical suitability) included?
- Who will own provider negotiation and patient communication activities for redirection?
- List any clinical or regulatory constraints (e.g., site accreditation, licensing) relevant to redirects.
Perform 340B Carve-In Recovery Transactions
- Do you have covered entity relationships or 340B carve-in exposure in your claims?
- Can your PBM provide 340B identifiers or subrogation flags in claims data?
- Do you want automated identification of potential 340B billing where plan overpaid?
- Should recovery workflows include outreach to covered entities, PBM dispute filings, and expected recovery tracking?
- What documentation is required to support 340B recovery claims (e.g., invoices, prescriber NPI lists)?
- Describe any sensitivities around 340B communication or stakeholder governance we should follow.
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Mutual Commit
Agree commercial terms, retainer scope for renewal window work, data SLAs, and governance for disputed contract interpretations.
Agreement Modules
- Statement of Work (SOW)
- Master Services Agreement (MSA)
- Commercial Schedule & Pricing
- Retainer & Renewal Window Scope
- Data Access & SLA Addendum
- Governance & Dispute Resolution
- Acceptance Criteria & Validation Plan
- Security & Compliance Addendum
- Payment, Invoicing & Refund Terms
- Change Order & Scope Amendment
- Independence & Conflict Disclosure
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Deployment
Operationalize ingestion, calibration, and governance for continuous NDC-level monitoring.
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Pre-Deployment Readiness
Confirm data formats, mapping rules, PBM cooperation plan, security controls, and owner responsibilities for ingestion.
Readiness Questions
Quick Snapshot — A Fast Look at Where You Are
- How many covered lives does this self-funded plan include today?
- When is the PBM contract up for renewal (month/year)?
- Who recommended your current PBM and what relationship, if any, do they have with that PBM?
- Roughly how much did pharmacy spend change year-over-year most recently (percentage) — pick the closest?
- What would you like us to understand first about your situation (brief summary in your own words)?
Is Your Renewal a Ticking Time Bomb?
- When you look at the renewal window, what's the single biggest risk that keeps you up at night?
- How confident are you that the PBM reporting today shows the true dollars flowing to your plan versus what the PBM retains?
- Can you share an example where a monthly or quarterly PBM report felt incomplete or misleading? What specifically raised doubts?
- How often have pricing surprises (rebate shortfalls, spread, MAC issues) required retroactive reconciliation or plan corrections in the past three years?
- If your PBM relationship continued as-is for another three years, what financial or operational consequences are you most worried about?
Who Really Holds the Keys? — Mapping Power, Influence & Bias
- Who will sign the PBM contract at renewal and who influences that decision the most?
- How aligned are the CFO, Director of Benefits, procurement, legal, and your benefits advisor on the objectives for pharmacy renewal?
- Have any advisors or consultants involved disclosed financial relationships with PBMs, manufacturers, or specialty pharmacies in writing?
- Who on your team will be the day-to-day owner for data requests, validation, and governance during an audit?
- How would you describe internal appetite for taking difficult actions (e.g., pausing payments, demanding reconciliations, or pushing for renegotiation) if audit findings require it?
Tell Me What Data Might Be Missing—But Matters
- If the PBM refused to deliver NDC-level claims or denied access to encounter files, how would that change your confidence in renewal decisions?
- Which of the following data artifacts can you currently provide or obtain from the PBM within 30 days?
- What formats do you receive claims and contract documents in today (E.g., CSV, EDI, PDF contracts, Excel)? List all that apply.
- What data gaps have blocked prior reviews from producing actionable NDC-level recommendations?
- Who in your vendor stack will need access to raw data for analysis (internal teams and external partners)?
What Would NDC-Level Clarity Actually Change for You?
- If you had verified NDC-level pricing and rebate pass-through detail, what decision would you most likely make differently?
- What minimum absolute dollar or percentage savings would you need to see at NDC level to justify changing vendors or renegotiating?
- When you review vendor savings pitches, what detail convinces you the number is real: NDC line-items, invoice-level reconciliations, or sample claims walkthroughs?
- How important is clinical validation (e.g., pharmacy director sign-off) versus pure dollar reconciliation for acceptance of an audit finding?
- Describe a decision you would take immediately if we surfaced a recurring generic overpayment or rebate shortfall.
Where Do Contracts Hide Money? — Reading Between the Guarantee Lines
- How confident are you that your PBM contract’s rebate language and MAC guarantees prevent retention of plan dollars?
- Have you ever disputed a PBM interpretation of a contract guarantee? What was the outcome?
- Which contractual elements matter most to you to verify during an audit?
- Can you upload or point to a redacted copy of the current PBM contract and exhibit(s) that define rebates and reconciliation rules?
- How long have you been operating under the current contract terms, and have those terms materially changed in that period?
How Ready Is Your Team to Act on Hard Findings?
- If an audit finds multi-million-dollar discrepancies, who on your team has authority to demand immediate remedial action (e.g., hold payments, seek clawbacks)?
- What internal blockers (political, contractual, vendor relationships) are most likely to slow or stop follow-through after findings?
- How quickly could your team convene a cross-functional governance group (Finance, Clinical, Legal, Procurement) to review audit findings?
- What training or handoffs would help your staff act confidently on contract compliance issues surfaced by an NDC-level audit?
- Who on your team should we include in technical onboarding and who should be the executive sponsor?
What Would Success Look Like—and How Will You Know?
- Beyond dollars saved, what outcomes would make you call this engagement a clear success?
- Which single metric will your CFO insist on seeing to approve a recommendation (e.g., net savings, rebate reconciliation, ROI over contract term)?
- What acceptance criteria (financial thresholds, reconciliation accuracy, clinical sign-off) must be met before your team considers a recommendation actionable?
- How often would you want to see progress reports during deployment and after go-live (cadence)?
- Who needs to sign off on final acceptance of audit outputs (finance, clinical, legal)? Please list roles.
If We Move Forward, What Could Stop It?
- What’s the most likely single thing that would derail a data-driven audit before it begins?
- Have you experienced pushback from a PBM during a previous data request or audit? What form did it take (delays, partial extracts, legal threats)?
- What contractual or legal protections would make you comfortable proceeding even if a PBM resists (e.g., audit clauses, holdbacks, escrow)?
- If we surfaced material non-compliance, how much internal political capital would you be willing to invest to pursue remediation?
- Are there external dependencies (broker approvals, board cycles, union negotiations) that could block timely decisions? Please specify.
Next Steps & Signals — What Would Make This Real?
- If we proposed a representative pilot using a 12–24 month claims window, how likely are you to authorize it given current circumstances?
- What internal approvals are required to engage an independent audit and who must sign the statement of work?
- Do you have a budget range or retainer tolerance for renewal-window advisory work?
- What would you need from us to present this engagement to your executive team with confidence (one-pager, sample findings, references, redacted case studies)?
- Who should we schedule a technical kickoff with if you decide to proceed (include name, role, and email if possible)?
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Deployment Enablement
Execute claims ingestion, contract rule configuration, benchmark calibration, and staff training with clear milestones and owners.
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Validation Checklist
Verify NDC-level audit accuracy, rebate reconciliation, MAC guarantee checks, and acceptance criteria against finance and clinical teams.
Validation Questions
Starting Point: Who's Actually in the Room?
- Who from your team will own the PBM renewal and be active in this discovery?
- What’s your current PBM contract end date (month/year)?
- How many months before renewal do you want final recommendations in hand?
- Which decision criteria will matter most when choosing next steps (select top 3)?
- What outcome would make your CFO say “this discovery was worth it” (be specific, $ targets or governance changes preferred)?
If Your PBM Report Was a Financial Statement, Would You Sign It?
- If I asked your CFO to explain exactly how rebates were applied last quarter, could they map rebates to NDCs and dollar amounts?
- On a scale from 'completely confident' to 'deeply skeptical', how do your finance and benefits teams view your PBM reporting?
- Where have you seen the biggest mismatches between PBM reporting and your internal expectations (select all that apply)?
- Tell a concrete story about a time your team questioned a PBM line item or rebate—what happened and what did it cost (if known)?
- How often do finance and clinical leaders meet to reconcile pharmacy spend concerns today?
Where the Dollars Might Be Slipping: What Are You Suspecting?
- Which area of your pharmacy spend do you suspect is most likely hiding excess cost right now?
- Approximately how much of your annual pharmacy spend is specialty vs. non-specialty today (percentage)?
- Have you seen recent spikes tied to specific drug launches or biosimilar dynamics? If so, which drugs or classes?
- Do you suspect inappropriate site-of-care billing or avoidable infusion facility utilization in your population?
- If you had to assign a financial risk band to these suspicions, what would it be?
What Would NDC-Level Certainty Change for You?
- If we delivered NDC-level audit evidence showing dollar-level discrepancies, how would that alter your renewal posture?
- Which internal stakeholders must see NDC-detail to greenlight action (select all that apply)?
- What minimum dollar or percentage savings would constitute an actionable finding for you?
- How definitive does the evidence need to be for you to pursue contract dispute or remediation (e.g., audit report + vendor response, legal opinion, independent expert)?
- What would a successful NDC audit look like in three months—describe the specific outputs you'd expect?
Trust & Independence: Let’s Be Crystal Clear
- How important is an advisor’s documented independence from PBMs/manufacturers when you evaluate recommendations?
- Have you required signed conflict-of-interest disclosures from advisors in previous renewals?
- Would your team require us to sign a formal independence disclosure before starting an audit?
- Have you worked with PBM-affiliated advisors before, and if so, how did that relationship influence outcomes?
- How would discovering an advisor conflict midway through a review affect your willingness to act on findings?
Data Reality Check: Can We Get What We Need?
- If the PBM resisted producing NDC-level claims extracts, what would you be willing to do to obtain them?
- Which of the following data sources can you access today or obtain within 30 days?
- How long (realistic estimate) would procurement or your PBM take to deliver complete NDC-level claims data?
- Do you have data-sharing agreements or legal permission to share de-identified claims with an independent auditor?
- Who internally will own pulling or approving datasets (name/role), and how do we coordinate with them?
What Keeps Procurement and Benefits Leaders Up at Night?
- What would be the reputational or financial fallout if a three-year renewal embedded hidden spread or retained rebates?
- Have past renewals included clauses that made auditing or verifying pricing difficult? If yes, which clauses (e.g., aggregate rebate pools, opaque aggregator language)?
- How involved is procurement in setting PBM contract acceptance criteria today?
- What operational constraints would limit your ability to change PBMs or contract terms at renewal (e.g., vendor relationships, employee benefit impacts, union agreements)?
- If a discovery shows significant overpayment, how much time would your team realistically need to act before renewal?
What Would a Successful Pilot Prove?
- If we ran a historical claims pilot, what single proof would convince you to move forward with a retainer for renewal work?
- Which KPIs must the pilot include to be considered successful (select up to 4)?
- What minimum dollar threshold would make a pilot ‘material’ for your finance team to act on?
- What deliverables and formats do your stakeholders expect from a pilot (e.g., slide deck, audit workbook with NDC line-items, executive summary)?
- Who must sign off on pilot results before you’d commit to a retainer (list roles and any required governance committee)?
Change Leadership: Who Will Carry This Forward?
- When we deliver findings that require hard conversations with your incumbent PBM, who will lead that negotiation internally?
- Who are the stakeholders that will resist change most, and what are their primary concerns (budget, relationships, operational burden)?
- What internal approvals are required to allocate a retainer for renewal work (roles and estimated approval time)?
- Have you previously executed a remediation or renegotiation with a PBM—what worked and what surprised you?
- Which support would make you most comfortable moving ahead after discovery (select top 2)?
Next Steps & Comfort Signals: What Do You Need to Proceed?
- If we proposed a 60–90 day discovery that includes an NDC pilot, what’s the smallest concrete sign-off you’d require to say ‘go’?
- What timing works for your team to start discovery (select earliest realistic start)?
- What are the top three blockers that would prevent you from starting discovery right away?
- How do you prefer we report interim findings while discovery is in progress?
- Any final concerns or questions you want us to address before a pilot scope is proposed?
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Success
Review achieved savings, contract compliance findings, and maintain a shared channel for issues and enhancement requests.
Success Reviews
- Executive Savings Review
- NDC-Level Findings & Contract Compliance Deep-Dive
- Reconciliation & Remediation Planning
- Operational Handoff & Shared Channel Setup
- Quarterly Success Review & Enhancement Roadmap
Issues & Enhancements
- Agree the intake and prioritization workflow for enhancement requests tied to business value.
- Obtain technical acceptance or a precise list of evidence required to resolve each disputed item.
- Create a clear mapping between contract clauses and observed behaviors for remediation or negotiation.
- Deliver a claim-level packet for each disputed item including raw claim extract, adjudication log, and contract excerpt.
- PBM/consultant to provide counter-evidence or written position within agreed SLA (e.g., 10 business days).
- Define the verification test for each disputed category (what evidence will close the dispute).
- Recap Accepted vs Disputed Items
- Select remediation paths for each accepted finding and agree on the primary negotiation or legal approach.
- Set clear deadlines and owners for recovery activities and PBM engagement.
- Agree on measurement rules to verify recoveries and avoid double-counting.
- Produce a Remediation Plan with itemized recoveries, chosen remediation route, and milestone calendar.
- Legal/Procurement to draft required contractual language or settlement memorandum for approved remediation items.
- Schedule weekly reconciliation syncs until recoveries are complete or disputes are escalated.
- Confirm Monitoring Baseline and Thresholds
- Launch a shared operational channel with agreed access, SLAs, and triage rules to support continuous monitoring.
- Ensure both vendor and customer operational teams understand runbook steps for handling new issues and false positives.
- Introductions & Objectives
- Create the shared channel and provision access for named owners; distribute channel guidelines.
- Publish the SLA matrix and runbook in the shared channel and schedule a 30-minute operational training.
- Establish the enhancement intake form and triage board for the next Quarterly Roadmap review.
- Quarterly KPI Review
- Validate ongoing savings and ensure transparency of open reconciliations and dispute resolution timelines.
- Agree the enhancement roadmap for the quarter that best protects or increases plan savings.
- Confirm metrics and owner commitments for the next review cycle.
- Publish the quarterly report with KPI dashboard, open dispute register, and roadmap commitments.
- Product/Platform to schedule delivery milestones for committed enhancements with acceptance criteria tied to business metrics.
- Operations to confirm next quarter monitoring thresholds and any updated runbook items based on recent incidents.
- Secure executive confirmation of verified savings and agreement on which findings are accepted vs disputed.
- Obtain sign-off on immediate remediation actions and governance escalation paths.
- Schedule the detailed technical deep-dive for disputed items and operational handoff.
- Publish a one-page Executive Summary (current state, consequence, future state, approved dollar recoveries).
- Schedule the 'NDC-Level Findings & Contract Compliance Deep-Dive' with required PBM/consultant attendees within 7 business days.
- Owner (Finance) to confirm acceptance criteria and list signatories for final acceptance within 3 business days.
- Pre-work confirmation
- Prove, with claim-level evidence, the examples that drive the majority of the measured savings.
- Current State (One-sentence)
- Remediation Options (Legal, Commercial, Operational)
- One-sentence Current State
- Open Issues & Dispute Status
- Shared Channel Configuration
- Timeline & Prioritization
- Consequence Summary (Financial & Operational)
- Representative Claim Walkthroughs
- Issue Triage & SLA Matrix
- Enhancement Backlog Prioritization
- Governance & Escalation Plan
- Roadmap Commitments & Success Metrics
- Future State Statement
- Enhancement Request Process
- Contract Clause Mapping
- Agreement on Measurement & Tracking
- Rebate Pass-through & Reconciliation Proofs
- Next Quarter Focus & Governance Actions
- Top-line Findings (NDC-level highlights)
- Runbook Walkthrough & Training
- Validation & Acceptance Check
- Assign Owners & Next Steps
- Validation Questions & Acceptance Tests
- Owner Confirmations & Access Grants
- Outcomes & Dispute Categorization