The URAC PBM Standards: Module 2: Customer Service, Communications, and Disclosure

This 12-standard module in the URAC PBM program focuses on required disclosures by the PBM to both the consumer and the client.

"Vanilla" Consumer Education Standards

CSCD 1 lists seven requirements for post-enrollment consumer information, reminiscent of P- MR 3 in the Health Plan standards. CSCD 2-4, 6, 8-11 are rather predictable (and familiar) transparency, accuracy, access, and readability standards for consumer communications of the sort one sees throughout URAC’s and/or Medicare’s standards for organizations that deal with consumers.

Records Verification

A particularly interesting standard, in no small way because it is a mandatory standard, is CSCD 5: “The organization has a mechanism to allow its clients to verify the organization’s records to ensure that the disclosures in CSCD 4 (c) are comprehensive and accurate, per the terms of the client contract.” The on-request disclosures to which this standard refers are “Pricing structure for pharmacy benefit management services, such as: (i) Rebate structure; and (ii) Administration fees.”

Specific Call Center Requirements

I was also interested in the rather specific call center requirements of CSCD 7 (“(a) Incoming calls must have an average speed of answer within 30 seconds, and (b) Average abandonment rate of all incoming calls cannot exceed 5 percent”). URAC has seldom been this specific in this domain of responsiveness to consumers, and may augur similar standards in future versions of other clinical programs.

Generic and Mail Order Programs

Besides CSCD 5, the only other mandatory standard in this module is CSCD 12: “Mandatory generic and mail order programs must offer educational information for the consumer.”

All in all, this module should present few challenges for PBMs with robust consumer communications programs.