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Revised January, 2010 CONFIDENTIAL AND PROPRIETARY - page 6 / 31





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General Walgreens Health Initiatives Policies

Access to and Retention of Records

Unless otherwise set forth in your Pharmacy Network Agreement with Walgreens Health Initiatives, records are required to be maintained and accessible for: (i) ten years following each year of the term in which the pharmacy provides Services under the Pharmacy Network Agreement or longer as mandated by CMS (Centers for Medicare and Medicaid), for Medicare Part D; (ii) six years for the Medicare Drug Discount Card; and (iii) five years or per applicable federal or state law, whichever is longer, for any other Walgreens Health Initiatives’ business records. Please refer to your Pharmacy Network Agreement with Walgreens Health Initiatives and applicable state and federal law for specific record retention requirements.

Compliance with Laws and Regulations

Pharmacies will comply with the terms of its Pharmacy Network Agreement with Walgreens Health Initiatives, as well as all applicable laws, rules, and regulations, including, without limitation, the Social Security Act, Medicare Part D implementing regulations, 42 CFR Parts 400-423, CMS instructions and the federal anti-kickback statute, 42 USC §1320a-7b(b), as any of which may be amended from time to time. In addition, the pharmacy will comply with any state specific Medicaid requirements, including any requirements applicable to pharmacy set forth in the contract between the plan sponsor and the applicable Medicaid agency, as a condition of participating in Walgreens Health Initiatives’ Medicaid network for such state(s). The pharmacy represents that neither it nor any of its owners, directors, officers, employees, or contractors are subject to sanction under the Medicare /Medicaid program or debarment, suspension, exclusion under any other federal or state agency or program, or otherwise are prohibited from providing services to Medicare or Medicaid beneficiaries. The pharmacy will notify PBM immediately of any change in such status. Any breach of the requirements and representations set forth in this paragraph is grounds for immediate termination by Walgreens Health Initiatives of the Pharmacy Network Agreement.

Signature Logs

The pharmacy shall maintain a signature log at each location listing the Plan Name, Prescription Number, and date of receipt, and require an eligible member or representative who receives a covered drug to sign the log. In certain situations delivery manifests may be acceptable, as determined by Walgreens Health Initiatives in its sole discretion. Other acceptable means of maintaining these data may be appropriate with Walgreens Health Initiatives’ written consent.

Confidentiality Requirements

Please refer to your Pharmacy Network Agreement with Walgreens Health Initiatives for specific confidentiality requirements, including HIPAA requirements and requirements regarding Walgreens Health Initiatives’ confidential and proprietary information.

Walgreens Health Initiatives – Pharmacy Manual


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