UPDATE: ESI Issues Recoupment Stay of Deadlines Until Further Notice
On July 1, 2020, pharmacies and industry stakeholders received information from ESI that (i) the Defense Health Agency (DHA) and ESI are reassessing the recoupment action, (ii) money that has already been recouped will not be refunded during the reassessment period, and (iii) the 90-day time period to submit information and documentation in support of a request for an administrative review is being stayed as of 6/23/20 until further notice.
If you go to the link, below, you will see the most recent whitepaper (dated 7/1/20) prepared by the attorneys at Brown & Fortunato, P.C., for the Alliance for Pharmacy Compounding and the National Community Pharmacists Association. The whitepaper discusses these new developments.
The balance of the whitepaper shares the new information from ESI, as directed by DHA, as well as guidance for impacted pharmacies as they seek legal counsel on this serious matter.
You may also be interested in our previous ESI recoupment blog post
about this matter.