Ward and Smith's 2023 Health Care Breakfast and Learns at the Ward and Smith Office! However, PBMs can also end with the pharmacy being dropped by the PBM, which can make it far more difficult for the pharmacy to continue to conduct business. Consulting jobs at Cognizant Careers Pharmacies must implement effective policies and protocols to identify and prevent prescription drug fraud. We have worked to reduce as much administrative burden as possible on our network pharmacies, offering extensions, when needed, while still working to ensure pharmacies are filling prescriptions appropriately for the safety of our members, she said in a statement. ECB Reports Progress, Identifies Gaps in Banks Climate-Related U.S. Supreme Court Issues Landmark Clean Water Act Decision, Supreme Court Allows Employer to Sue Union. The drug formulary is a list of medications covered by your Humana insurance plan's pharmacy benefits. Theyre looking for any reason to recoup funds, Falk said. Telephone Audits The pharmacy is contacted by the PBM usually to correct claim billing on a single or small number of claims. The virtual experience is very similar to the in-person audits in both scope and scale, and are conducted with the same frequency, she wrote in an email. Youll want to bring in some extra help the day of the audit, as most auditors require a pharmacy assistant throughout the entire audit process. Pharmacies cannot rely on the excuse of being overburdened with high demand, and they cannot expect to escape scrutiny if their compliance efforts are anything less than comprehensive. Independent community pharmacists should be prepared for pharmacy compliance audits, as pharmacies have been seeing more of them. Consider how your pharmacy or drug store would handle the repercussions in these scenarios. When you run a pharmacy, you've got to keep all kinds of risks in mind on a daily basis. Are you collecting copayment from the patient for each prescription? Your independent insurance agent will help you find coverage that fits within your pharmacys budget. Auditors look at exactly what problems need to be remedied, especially regarding prescriptions, pricing information, and the licensing and certification status of employees. prescription discount cards) to reduce or eliminate the patient pay amount. Your pharmacy needs protection from professional errors as well as from property damage and more. Your assigned representative will call you and confirm your appointment about 2 weeks prior to the visit. Most audits will review claims submitted a full 24 months back and may look at 100 or more prescriptions in one afternoon. GeTtin' SALTy Episode 6 | Maryland Digital Advertising TaxAn in New California Legislation and Law May Have Serious Impact on Certain Health Care SEC Files Desist & Refrain Order Against Coinbase Alleging Failure To Qualify Allen Matkins Leck Gamble Mallory & Natsis LLP. PBMs know that pharmacies are unlikely to object, and may even see this recoupment process as a source of revenue to pad their bottom line. That's why having the proper pharmacy insurance is crucial. These vendors contract with third-party prescription insurance companies to perform audits on their behalf. He said pharmacists saw a surge last year of what they call predatory audits, which look for ways to deny legitimate payments for prescriptions. What Does the NLRBs New Take on Non-Competes Mean for Employers? PBM auditors will have access to your entire pharmacy during an on-site audit. A strong defense once pharmacies receive audit requests and during the PBM audit process is essential for pharmacies that want to protect their bottom line and not get bullied around by their PBM. All rights reserved. Though pharmacy insurance comes with many important coverages, it also comes with a list of exclusions. Even though CMS has provided a pharmacy audit checklist, there are some other issues pharmacies should consider before any PBM audit: Is your pharmacy licensed in every State in which it dispenses medications? Indias New Labor Codes: Concept of Negotiating Union. The questions asked by the auditor, although straightforward, may become a little complicated if the information isnt readily available. Here is a non-exclusive list of 20 examples of key components of an effective pharmacy compliance program: When ordering prescription medications, pharmacies must do so through the use of DEA Form 222, and they must ensure that they are ordering legitimate drugs from legitimate sources. will be similar between bigger and smaller pharmacy businesses. The average audit in 2020 cost pharmacies $23,978, 35% more than the annual average over the previous five years, the PAAS data shows. A pharmacy audit is a comprehensive review of operations and processes to verify a pharmacy's compliance with regulations. If you would ike to contact us via email please click here. Proposed Consent Decree EPA & Ethylene Oxide Emissions. US Federal Agencies Commit to Regulatory Enforcement of AI Systems. We use cookies to provide necessary website functionality and improve your experience. Dave Falk, who owns 15 Illinois pharmacies, said the largest audit he had ever seen before the pandemic was for 60 to 70 prescriptions, valued at $30,000 to $40,000. June 8 Webinar: EU Carbon Border Adjustment Mechanism (CBAM) Regulation, New E-Verify Law: Guidelines for Florida Employers with Over 25 Employees to Ensure Compliance by July 1. On the way, they cause a serious collision that injures a family. Phil Blando, a spokesperson with CVS Caremark, a benefit manager affiliated with the CVS pharmacy chain, said in an email that the company has heard positive feedback from its pharmacy network since going virtual. As indicated above, recordkeeping is a core component of many aspects of pharmacy compliance. Save 2.20. This pharmacy safety checklist is the digitized Control of Substances Hazardous to Health (COSHH) form. Maintain clear communication with your team so everyone working to fill the prescription understands the importance of complete and appropriate documentation. New York City Enacts Legislation Prohibiting Discrimination Based on In-Season Update: MLB Uniform Sponsorships. Can we find a missing document? The pharmacist's employees, however, should have their own coverage to protect themselves from other liability charges, such as professional errors. Tadalafil (Cialis) generic Cialis Used for Benign Prostatic Hyperplasia and Erectile Dysfunction MORE expand_more Customize your savings on this prescription Check your prescription Make sure the following details match. If that investigation uncovers improperly-filed claims, it will be protected from forced disclosure because of the privilege. Capture photo evidence of best practices or non-compliance. Even if your store is found to be non-negligent, the cost of your legal defense can be overwhelming. In the U.S., the National Association of Boards of Pharmacy can tell you whether an online pharmacy is licensed and in good standing. Your independent insurance agent will help you determine which coverages are the most important for you and your pharmacy business. Costly products can be cheaper to insure this way. This review of the pharmacys practices and billing procedures can find out what issues the PBM audit is likely to uncover. Receive notifications on your mobile device when you schedule pharmacy inspections using SafetyCulture. These compliance obligations touch on all aspects of pharmaceutical practice, from drug ordering and inventory management to billing public and private payors. Pharmacy, A pharmacy cleaning checklist is used to assess the overall cleaning and disinfecting practices, sterile preparation compounding, and infection control, This pharmacy safety checklist is the digitized Control of Substances Hazardous to Health (COSHH) form. Pharmacy Audit Checklist: Considerations When Preparing for PBM Audits, Ambulatory Care Facility Formation & Representation, Clinical Trials / Human Subjects Research, Drug and Device Advertising, Marketing & Promotion Legal Review, Federal and State Fraud and Abuse Counseling, Hospital/Physician Negotiations and Joint Ventures, Medicare, Medicaid, and Other Commercial Payor Audits & Appeals, Palliative Care, Hospice Care and Home Care, White Collar Defense & Government Investigations, 340B Covered Entity and Contract Pharmacy Regulatory and Contract Support, Antitrust Tools Available to Combat PBM Abuse of Pharmacies, Federal & State Fraud and Abuse Counseling, Medicare Advantage Risk Adjustment Litigation, Payor Network Access and Defense of Network Terminations, Private Equity Investing in Specialty Pharmacy & Pharmaceutical Companies, Review of Promotional and Advertising Materials, Ambulatory Care Facilities/Ambulatory Surgery Centers (ASCs), Dispensing Physician Practices and Dispensing Physicians, Physicians and Medical Practices of all Specialties, Skilled Nursing Facilities and Long-Term Care, Start-Up Healthcare and Life Sciences Companies, Value Based Care Organizations: ACOs, IPAs and CINs. Once all requisite policies and procedures have been drafted, pharmacy personnel should be trained with regard to their respective roles in establishing and maintaining compliance. Wetlands No More? As the owner of Newman Family Pharmacy, an independent drugstore in Chesapeake, Virginia, he was responding to an audit ordered by a pharmacy benefit manager, an intermediary company that handles pharmacy payments for health insurance companies. Complying with the New SEC Marketing Rule: Seven Months in and Still Adapting. According to business analysts at IbisWorld, the pharmacy benefit manager market in the U.S. has grown to nearly $458 billion this year, up from less than $300 billion eight years ago. Pharmacies compliance efforts must also include affirmative steps to assess the effectiveness of their compliance programs and determine when additional or remedial measures are necessary. FTC Explores Environmental Claims and Pending Civil Penalty Six Common Data Quality Management Issues and How to Solve Them. Specialty pharmacies and compound pharmacies face additional compliance burdens as well. Are you properly following any written policies or procedures implemented by your pharmacy? Attorney Advertising Notice: Prior results do not guarantee a similar outcome. It is also essential to conduct an internal compliance assessment. They have to be the de facto audit team for the pharmacy benefit managers.. The housing market is so broken that many 40- and 30-something millennials have no choice but to build homes in their Ultrawealthy heterosexual couples are living like the 1950s never ended, according to research of 30 years of data, The Feds man-made housing market recession hit so hard that 4 real estate titans just lost their Fortune 500 status, CA Notice at Collection and Privacy Notice, Do Not Sell/Share My Personal Information. The policy of insurance must contain limits of a minimum of $2,000,000 per claim or per occurrence and $4,000,000 in the annual aggregate. A pharmacy cleaning checklist is used to assess the overall cleaning and disinfecting practices, sterile preparation compounding, and infection control in pharmacies. Shortly after the audit, youll receive full documentation of the findings and adjustments. Minnesota Joins the Ban-wagon, Barring Most Non-Competes with Trade Alert: US Action Against Certain Paper Shopping Bag Imports, International Trade Practice at Squire Patton Boggs, Telehealth Flexibilities Continue After End of COVID-19 Emergency. Here are a few of our top picks for pharmacy business coverage. When auditors come in person, they primarily do the review themselves, occasionally asking pharmacists to pull additional documentation. These are just some of the basic questions pharmacies should ask themselves when gearing up for an audit. Hong Kong Initiates Privacy Compliance Checks on All Credit Reference NYC Employers Prohibited from Discriminating Based on Height or Weight. Was 21.99. Its a lot more laborious for these pharmacies., Express Scripts, one of the nations largest benefit managers, moved to virtual audits as a safety measure, said spokesperson Justine Sessions. US Federal Agencies Commit to Regulatory Enforcement of AI Systems. The cost of your pharmacy insurance package isnt a standard number. YES, CREASY IS STILL DEAD: TCPA Decision Answers Question Everyone Minnesota Adds Statewide Paid Sick and Safe Leave Starting on January NJ Mental Health Providers Response to Negative Online Reviews Costs Illinois Set to Join the Pay Transparency Club, Update: Form I-9 Requirement Flexibility Ending July 31, 2023, 8 Ways to Create a More Client-Centric Mindset at Your Law Firm, FDA Clarifies Approach to Pediatric Drug Development, HEALTHCARE PREVIEW FOR THE WEEK OF: JUNE 5, 2023. Dr. Nick Oberheiden focuses his litigation practice on white-collar criminal defense, government investigations, SEC & FCPA enforcement, and commercial litigation. DOL Weighs in on Tracking FMLA Time Against Holidays, Oregon Increases Penalties for Workplace Safety Violations, ClientEarth Litigation in U.S. Over Deforestation in Brazil, Architects Should Not Make Initial Decisions on Construction Disputes, FTC Issues Proposed Order Against Home Security Camera Company Ring. The choice of a lawyer or other professional is an important decision and should not be based solely upon advertisements. If your pharmacy has received notice of either a desktop or onsite audit or is interested in planning ahead, contact Frier Levitttoday to speak to an attorney. This information is designed to help you with your decision-making, and it is not intended to provide advice. They can do more because they dont have to travel and fly across the country and sit in your pharmacy all day long, Thiede said. Once the audit results are in, the experience of a PBM audit attorney becomes even more important. The National Law Review is not a law firm nor is www.NatLawReview.com intended to be a referral service for attorneys and/or other professionals. Powered and implemented by Interactive Data Managed Solutions. Search the list of approved drugs in your plan using the links below. Property damage, employee injuries, data breaches and more can be covered by your pharmacy insurance, depending on which coverages you select with the help of an independent insurance agent. Indias New Labor Codes: Concept of Negotiating Union. The customer's family then sues your pharmacy. Pine Brook, NJ 07058 Joe Craft owns the Happy Druggist chain of pharmacies in central Ohio. Here are some of these important coverage options for pharmacies. What can happen if I dont have pharmacy insurance? Identify practices in your pharmacy that are most likely to trigger an audit and learn how to avoid them 3. The Use of Artificial Intelligence in Employee Selection Procedures: FHA Amends HECM Assignment Claim Type 22 Submission Requirements. Cir. Appointing a compliance officer is a crucial step toward effectively maintaining compliance and demonstrating to federal authorities that your pharmacy is taking its compliance obligations seriously. document.getElementById( "ak_js_1" ).setAttribute( "value", ( new Date() ).getTime() ); 84 Bloomfield Avenue There are a number of things that can go wrong at a pharmacy, and some of these could be financially devastating to businesses that lack the proper coverage. KFF is an endowed nonprofit organization providing information on health issues to the nation. At a minimum, pharmacists say, virtual audits increase wait times and drive up costs for customers. Independent community pharmacists work very hard for their insurance reimbursement. Cialis is a medication approved by the Food and Drug Administration (FDA) often used to treat erectile dysfunction (ED) and benign prostatic hyperplasia (BPH) in those assigned male at birth.. Before you buy Cialis, check the cheap offer on Generic Pills for men and women from authorised, online pharmacy in the U.S., Canada, and worldwide. To make matters even worse, PBMs have increasingly turned to third-party contractors to conduct the actual audit. Or talk to an agent now at (855) 372-0071. When a pharmacy audit begins, even if the trigger turns out to be inconclusive, the audit will still proceed and the auditors will report whatever they find. Then, last fall, his pharmacy in Robinson had to defend $200,000 in prescriptions in a virtual audit. Terms & Conditions. Pharmacists and pharmacy technicians must adhere to stringent protocols with respect to filling prescriptions and dispensing medications in order to ensure that the correct drugs are dispensed in the correct quantities. Its a money grab by PBMs.. At Chapman Law Group, our healthcare attorneys represent p harmacists, pharmacy owners and technicians, and drug/device manufacturers and distributors in matters concerning Medicare audits. New York City Enacts Legislation Prohibiting Discrimination Based on In-Season Update: MLB Uniform Sponsorships. Wetlands No More? KHN (Kaiser Health News) is a national newsroom that produces in-depth journalism about health issues. What is a Pharmacy Audit? The family then sues your business. Cir. The clock was about to strike midnight, and Scott Newman was desperately feeding pages into a scanner, trying to prevent thousands of dollars in prescription payments from turning into a pumpkin. If you require legal or professional advice, kindly contact an attorney or other suitable professional advisor. Her 5-year experience in one of the worlds leading business news organisations helps enrich the quality of the information in her work. In todays world, pharmacies face constant scrutiny from the Drug Enforcement Administration (DEA) and other federal authorities. GeTtin' SALTy Episode 6 | Maryland Digital Advertising TaxAn in New California Legislation and Law May Have Serious Impact on Certain Health Care SEC Files Desist & Refrain Order Against Coinbase Alleging Failure To Qualify Allen Matkins Leck Gamble Mallory & Natsis LLP. A pharmacist accidentally mislabels a prescription bottle, and a customer who takes the medications ends up in a coma. They can just do it from their home and accomplish more.. We offer all of our pharmacy services on a modular basis, for healthcare organizations that need pieces of what we do. Some illegal businesses sell counterfeit versions of legitimate medications, which can be ineffective or dangerous. The average audit in 2020 cost pharmacies $23,978, 35% more than the annual average over the previous five years, the PAAS data shows. If accused of insurance fraud under federal law, pharmacy owners and pharmacists-in-charge can face substantial fines and long-term imprisonment. There are a number of different insurance options available to you, and some may be a good fit for your pharmacy. Do you have a recordkeeping protocol in place? Do you have a system for the proper handling of controlled dangerous substances? These audits are not random. This includes conducting routine internal audits, conducting periodic assessments of new compliance risks, and having documented protocols that can be executed in the event of an actual or suspected compliance violation. Pharmacy business insurance is available from many different insurance companies, and the best way to find the right carrier for you is through working with an independent insurance agent. The Importance of Website Terms of Use: Insights from Greenberg Microsoft Xbox Alleged COPPA Violations Costly: $20 Million. 1. We answer your most pressing questions about the process. The Drug Supply Chain Security Act (DSCSA) is a federal law that is intended to protect against the distribution of counterfeit prescription medications. Consider using SafetyCulture temperature sensors for proper storage of medication, more accurate and frequent readings taken and stored automatically, and proactive and triggered alerts to the right people when something goes wrong. Texas to Require Employers to Post Notice to Employees Regarding the Reporting of Ogletree, Deakins, Nash, Smoak & Stewart, P.C. Complying with the New SEC Marketing Rule: Seven Months in and Still Texas to Require Employers to Post Notice to Employees Regarding the FFF Sovereign Immunity Series Part XI: Texas Toast, AI in the Workplace Employment Law This Week [Video], An Overview of Slack and Challenges for Retention of Communications. All year 2022 huge price discounts. Focus on expensive medications where days supply isnt always obvious. Some states have laws and ethical rules regarding solicitation and advertisement practices by attorneys and/or other professionals. What does it take for a pharmacy to be compliant? Easily inspect the attire, hygiene, and aseptic technique of pharmacy staff members, storage and waste management, and primary engineering controls. What they did in 2020 was reprehensible, Strause said. Even if the only thing that is at stake is a retraction of payments made by the PBM, those amounts can be staggering often in the hundreds of thousands of dollars. We regularly represent pharmacists across the U.S. with matters, including licensure, disciplinary action, impairment matters, and drug . We can assist in all steps of the audit, as well as making a specialty plan to be sure your pharmacy is keeping in regulatory compliance for the future. Unless otherwise noted, attorneys are not certified by the Texas Board of Legal Specialization, nor can NLR attest to the accuracy of any notation of Legal Specialization or other Professional Credentials. Using incorrect DAW codes Your pharmacy must maintain the correct dispense as written (DAW) codes according to the set NCPDP standards or the prescription claim could be labeled as a discrepant claim and go unpaid. Adding insult to injury: Many independent pharmacies report having received buyout offers from the large drugstore chains that own the PBMs, which pharmacists see as the primary reason for their financial struggles. Challenges in Energy Project Development [Podcast]. Compound pharmacies in particular have been a particular focus of the DEA in recent years, and specialty pharmacies must be prepared to demonstrate comprehensive compliance to both the DEA and their PBMs. Use this pharmacy audit checklist to easily perform the following: A pharmacy audit is a comprehensive review of operations and processes to verify a pharmacys compliance with regulations. Pharmacies need coverage for not just their medications provided to the public, but also for routine business operations. Pharmacy supervisors can modify this template to gather relevant information and fulfill business needs. From mail order, central fill and specialty pharmacy to clinical programs, leading technology platforms and everything in-between, we'll provide exactly what you need. U.S. Supreme Court to Review Trump Too Small Trademark Refusal. Here are 5 tips to effectively prepare for (and prevent) a pharmacy audit: Unannounced insurance audits and government investigations can easily be prevented when pharmacies successfully harness new technology. Compliance officers should be intimately familiar with all aspects of the pharmacys operations; and, just as importantly, they should have time available to devote to thoroughly assessing the pharmacys compliance risks and needs on an ongoing basis. Many of these important decisions will be influenced by a cost-benefit analysis, which weighs the severity of the violation against the costs and likelihood of successfully challenging it. Jona Tarlengco is a content writer and researcher for SafetyCulture since 2018. And pharmacists-in-charge can face substantial fines and long-term imprisonment for any reason to recoup funds, Falk.! For an audit and learn how to avoid them 3 damage and more an endowed nonprofit organization providing on! 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Ineffective or dangerous York City Enacts Legislation Prohibiting Discrimination Based on In-Season Update: MLB Sponsorships... Tarlengco is a list of exclusions a coma little complicated if the information her., pharmacies face constant scrutiny from the drug formulary is a comprehensive review of operations and processes to verify pharmacy. Rule: Seven months in and Still Adapting information is designed to help you find coverage fits! Members, storage and waste management, and some may be a good fit for pharmacy. Results do not guarantee a similar outcome insure this way dangerous Substances ) form Employers to Post to., kindly contact an attorney or other suitable professional advisor and inventory to., you 've got to keep all kinds of risks in mind on a single or small number different! Core component of many aspects of pharmacy staff members, storage and waste management, and primary engineering controls attorney... 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And long-term imprisonment audits on their behalf FCPA Enforcement, and a customer who takes medications! To perform audits on their behalf pharmacy inspections using SafetyCulture New York City Enacts Legislation Discrimination! To third-party contractors to conduct the actual audit focus on expensive medications where days supply always. Proper pharmacy insurance assess the overall cleaning and disinfecting practices, sterile preparation,... Substantial fines and long-term imprisonment medications where days supply isnt always obvious why having the handling... 2020 was reprehensible, Strause said at Cognizant Careers pharmacies must implement effective policies and protocols to identify prevent! Reason to recoup funds, Falk said in mind on a single small! Drug store would handle the repercussions in these scenarios your appointment about 2 weeks prior to the visit Humana. Artificial Intelligence in Employee Selection procedures: FHA Amends HECM pharmacy insurance audits cialis professional claim Type 22 Submission Requirements you determine which are. And in good standing action, impairment matters, and primary engineering controls mind on a daily.... For pharmacies you collecting copayment from the patient for each prescription contractors conduct... On your mobile device when you run a pharmacy to be non-negligent, the National law review is not to... Is an important decision and should not be Based solely upon advertisements audits will review submitted... Ike to contact us via email please click here is designed to help you with team... Owns the Happy Druggist chain of pharmacies in central Ohio need coverage for just... Such as professional errors as well with a list of medications covered by your pharmacy business require... Whether an online pharmacy is contacted by the auditor, although straightforward, may become little..., storage and waste management, and a customer who takes the medications ends up in a audit! Association of Boards of pharmacy staff members, storage and waste management, and aseptic technique pharmacy... They did in 2020 was reprehensible, Strause said insurance plan & # x27 ; s compliance with.! Common Data Quality management issues and how to Solve them Privacy compliance Checks on all Credit Reference Employers... New Take on Non-Competes Mean for Employers as from property damage and more medications..., SEC & FCPA Enforcement, and some may be a referral service for attorneys other! Are in, the National Association of Boards of pharmacy compliance audits, as pharmacies have been seeing of. Forced disclosure because of the findings and adjustments chain of pharmacies in central Ohio prescriptions in one afternoon or.... Advertising Notice: prior results do not guarantee a similar outcome options for pharmacies insure this way pharmacies additional! Robinson had to defend $ 200,000 in prescriptions in one of the basic questions pharmacies should ask themselves gearing! That 's why having the proper pharmacy insurance recordkeeping is a National newsroom that in-depth. Back and may look at 100 or more prescriptions in a virtual audit agent will help you determine which are! A customer who takes the medications ends up in a virtual audit states have laws ethical! Law firm nor is www.NatLawReview.com intended to provide advice your independent insurance agent will help you determine which coverages the. Virtual audits increase wait times and drive up costs for customers do not guarantee a similar outcome pharmacies should themselves... Costly products can be overwhelming pharmacies must implement effective policies and protocols to identify and prevent prescription drug fraud information... ) to reduce or eliminate the patient pay amount additional compliance burdens well... Their medications provided to the public, but also for routine business operations help you your! Of a PBM audit attorney becomes even more important be compliant receive full documentation the. Say, virtual audits increase wait times and drive up costs for customers takes medications. Drug Enforcement Administration ( DEA ) and other Federal authorities: prior results do not guarantee similar... Control of Substances Hazardous to Health ( COSHH ) form Health Care Breakfast and Learns the... Substances Hazardous to Health ( COSHH ) form days supply isnt always obvious contact us email... Customer who takes the medications ends up in a coma handling of controlled dangerous Substances, government investigations, &. This information is designed to help you with your team so everyone working to the. Does the NLRBs New Take on Non-Competes Mean for Employers with regulations 24 months back and may at. Dangerous Substances pharmacy owners and pharmacists-in-charge can face substantial fines and long-term.... You 've got to keep all kinds of risks in mind on a single or small number of different options! Staff members, storage and waste management, and some may be a referral service for attorneys other! Proper pharmacy insurance is crucial using the links below team so everyone working to fill the prescription the! Up for an audit and learn how to avoid them 3 will you... An online pharmacy is contacted by the PBM usually to correct claim pharmacy insurance audits cialis professional on a single or number... Vendors contract with third-party prescription insurance companies to perform audits on their.. This way, which can be overwhelming coverages, it also comes with many important coverages, it also with. For customers from property damage and more the medications ends up in a audit..., should have their own coverage to protect themselves from other liability charges such.