Our latest thoughts and inspirations on buying a pharmacy, starting a pharmacy, and ongoing pharmacy operations

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Today we are pleased to share this timely white paper titled "STRUCTURING COVID-19 PROTOCOLS FOR PHARMACIES" from one of our partners - the law firm of Brown & Fortunato, P.C.


We are facing an unprecedented challenge. COVID-19 has spread rapidly across the world
affecting workforces, global economies, and everyday individuals. While the virus has seemingly
turned the world as we know it upside down, good news is on the horizon. Through concerted
efforts of social distancing in the United States, it appears that the “curve is flattening” and states
are slowly beginning to reopen. With states reopening, pharmacies need to implement controls
that will not only protect the safety and health of its employees, but also its patients.

The motivation for a pharmacy to properly reopen is obvious and includes: (i) the desire to take
care of its patients; (ii) the desire to take care of its employees; (iii) the desire to keep its doors
open; and (iv) the desire to protect itself from plaintiffs’ attorneys who will likely come out of
the woodwork six months from now and sue pharmacies for negligence.

The purpose of this white paper is to provide guidance to pharmacies on structuring an
appropriate written protocol that implements necessary controls including: (i) what reliable
governmental sources a pharmacy can turn to for COVID-19 guidance; (ii) recommended
controls for pharmacy employees; and (iii) recommended controls for pharmacy patients.

Download the full White Paper in PDF format
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Mark Nelson Joins Independent Rx Consulting as Partner and Vice President of Business Development

Mark Nelson Joins Independent Rx Consulting as Partner and Vice President of Business Development

Independent Rx Consulting Expands Executive Team with Key New Hire

Dayton, OH,  May 11, 2020

Mark Nelson, Partner and Vice President of Business Development

Independent Rx Consulting is pleased to announce and welcome Mark Nelson as Partner and Vice President of Business Development.

His primary role will be to develop and execute a broadened range of new value added sales initiatives. Mark is uniquely positioned to expand Independent Rx Consulting's services offerings via his proven expertise in strategic sales planning, relationship building, and passion for helping independent pharmacies succeed.

“There are few people in the industry who could provide our current and future clients the depth of knowledge he will bring. He is a key addition to our executive team.” says Owen BonDurant, Partner at Independent Rx Consulting.

Mark has over a decade of experience in the independent pharmacy industry, most recently as Vice President of Sales at PioneerRx, a leading pharmacy software company. From installing software and training staff to helping industry leaders optimize their pharmacy operations, Mark’s extensive technology background, industry experience and business development skills will be instrumental in helping Independent Rx Consulting continue to expand both its service offerings and industry reach.

“I am beyond thrilled to be a part of the Independent Rx team,” said Mark. “I have the ability to continue working with the customers I know and love in an industry that I’m extremely passionate about. For years I’ve worked with pharmacists to help them realize their dream of owning their own business, and it feels good to take the same leap myself.”

Clients and friends are invited to send their messages of congratulations and welcome.

Independent Rx Consulting provides business services addressing needs throughout the entire life cycle of independent pharmacy ownership, from the initial purchase or starting of the pharmacy to its ultimate transition. Services offered at all stages of the pharmacy ownership life cycle include accounting, data dashboards, operational consulting and start/buy consulting.  

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Health & Human Services CARES Act Payments

Many of you may have received deposits this past week from the Department of Health & Human Services and if you have not you may this week.  These payments apply to Medicare Part B billings only. Below is an outline of what this program entails.  

The President signed the bipartisan CARES legislation that provides $100 billion in relief funds to hospitals and other healthcare providers on the front lines of the coronavirus response. Recognizing the importance of delivering funds in a fast and transparent manner, the Department of Health and Human Services (HHS) is distributing $30 billion of the relief funds immediately. These are payments to healthcare providers, not loans, and will not need to be repaid.

Who is eligible for funds from the initial $30 billion?

Billing entities who received Medicare fee-for-service (FFS) reimbursements in 2019 are eligible for this initial rapid distribution.

If y
our organization qualifies and you will automatically receive payment soon.

If your business operations ceased as a result of the COVID-19 pandemic, you are still eligible to receive funds so long as you provided diagnoses, testing, or care for individuals with possible or actual cases of COVID-19. Care does not have to be specific to treating COVID-19. HHS broadly views every patient as a possible case of COVID-19.

How are payment amounts determined?

Providers will be distributed a portion of the initial $30 billion based on their share of total Medicare FFS reimbursements in 2019. Total FFS payments were approximately $484 billion in 2019.

  • A provider can estimate their payment by dividing their 2019 Medicare FFS (not including Medicare Advantage) payments they received by $484,000,000,000, and multiply that ratio by $30,000,000,000. Providers can obtain their 2019 Medicare FFS billings from their organization's revenue management system.

    • As an example: A community hospital billed Medicare FFS $121 million in 2019. To determine how much they would receive, use this equation:

$121,000,000 / $484,000,000,000 x $30,000,000,000 = $7,500,000

How will payments be distributed?

HHS is partnering with UnitedHealth Group to deliver funds. You will receive payment within two weeks via Automated Clearing House (ACH) to the Medicare routing number and account number you have on file with HHS. The automatic payments will come via Optum Bank with “HHSPAYMENT” as the payment description. Payments to practices that are part of larger medical groups will be sent to the group’s central billing office. All relief payments are made to provider billing organizations based on their Taxpayer Identification Numbers (TINs).

What action should I take?

Within 30 days of receiving the payment, you must sign an attestation confirming receipt of the funds and agreeing to the terms and conditions of payment. Terms and conditions can be found on hhs.gov/providerrelief. Should you choose to reject the funds, you must also complete the attestation to indicate this. The Payment Portal will guide you through the attestation process to accept or reject the funds. Not returning the payment within 30 days of receipt will be viewed as acceptance of the Terms and Conditions.

UPDATE: The CARES Act Provider Relief Fund Payment Attestation Portal  is now open. Providers who have been allocated a payment from the initial $30 billion general distribution must sign an attestation confirming receipt of the funds and agree to the terms and conditions within 30 days of payment.

What conditions are there?

As a condition to receiving these funds, providers must agree not to seek collection of out-of-pocket payments from a COVID-19 patient that are greater than what the patient would have otherwise been required to pay if the care had been provided by an in-network provider.

What is going to happen to the remaining 70 Billion?

The Administration is working rapidly on targeted distributions that will focus on providers in areas particularly impacted by the COVID-19 outbreak, rural providers, providers of services with lower shares of Medicare reimbursement or who predominantly serve the Medicaid population, and providers requesting reimbursement for the treatment of uninsured Americans.

Whom can I contact for more information?

For additional information, please visit hhs.gov/providerrelief or call the CARES Provider Relief line at (866) 569-3522.

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CARES Act - PPP Program Loan Forgiveness Update


Paycheck Protection Program Forgiveness Rules

Disclaimer - The  following information is based on current information available and is preliminary in nature pending final guidance from the SBA.

Many of you have now been approved for a Paycheck Protection Program Loan (PPP) and many have already received the funds from the government in your bank account.  For those of you who have not been approved please be patient as it is our understanding the second round of funding will begin this week (if you have not applied or do not have an approval it is still first come first serve so please get your application to your bank ASAP).

The rules for applying for many were complicated and we tried to provide details on this process.  If you have not applied please follow this link for details https://www.independentrxconsulting.com/blog.  

As most of you know these loans can be forgiven.  Unfortunately the forgiveness process and tracking is going to be significantly more complicated.  These rules are fluid and we will be providing updates as we learn more but the below is what we know thus far.

Please note working with your lending institution is very important as each bank may interpret these rules differently and understanding your bank’s interpretation is crucial to ensure that you maximize the amount of your loan which is forgiven.

What are the requirements?

You must use at least 75% of the proceeds for payroll costs.  The other 25% can be used on utilities, rent and mortgage interest that were in effect before February 15, 2020.

The loan proceeds are to be used to cover these costs over the 8-week period after the loan is made.

Employee counts or compensation levels must be  maintained or restored to maximize the forgiveness amount.

How much of the loan is eligible for forgiveness?

Up to 100%, if the above requirements were met.

What is included in Forgiven Payroll Costs?

  • Salary, wage, commissions

  • Payment of cash tips 

  • Payments for sick, vacation, parental, family or medical leave.

  • Dismissal or separation allowance

  • Dollars for group health care benefits, including insurance premiums

  • Payments for retirement benefits

  • Payment of state or local tax on employee compensation.

  • Notes On Mortgage and Rent Obligations

    • Only mortgage interest payments, not principal are eligible.

    • Mortgage or lease agreements must have been in effect prior to February 15, 2020

    • Rent payments made to a real estate holding company that you own are NOT Eligible.

What is considered a Utility?

  • Eligible utility payments are defined as electricity, gas, water, transportation, telephone or internet.

  • Pharmacy systems are not considered a utility.

Can I pay rent early?

Many people are asking can I pay a third rent early to ensure use of the dollars?  It is our present understanding you cannot.

Can I pay payroll early?
Many are asking can I pay my last payroll of the 8 week period early to ensure I use the dollars.  It is our understanding that dollars must be paid as has been done in the ordinary course of business and as such this cannot be done.

To what extent can bonuses be forgiven, or salary if it exceeds the amount included in the 12-month period used to calculate loan amount?

  • What we know: Salary is a forgivable expense.

  • What’s unclear: Can bonuses paid during the eight-week period be forgiven? What if the bonus causes the employee’s annualized salary to exceed the 12-month salary that was used to determine the loan amount (excess salary)? Is back pay or forward pay included in the forgiveness amount?

  • Insights: It is unlikely that forgiveness was intended to cover excess salary or forward pay, unless perhaps forward pay is the norm for the employer and it becomes due during the eight-week period.

What if my loan is not completely Forgiven?

The unforgiven amount will have an 18 month term at an interest rate of 1%.  This will operate just like a traditional loan with monthly payments to your bank.  These payments will not begin for 6 months but will accrue interest during this period.

How do I calculate Forgiveness?

Forgivable Portion (FP) = Payroll costs (PC) + any applicable mortgage interest payments (MIP) + any covered utility payment (UP) or FP=PC+MIP+UP

What Documentation Will you need to provide to be approved for forgiveness?

  • Proof of Payroll

  • Proof of utility payments

  • Proof of Mortgage interest payments or rent payments

  • Proof that you have maintained wages and staff.

  • Each lender may have other documentation requirements.

  • The lenders have 60 days to verify and process the loan forgiveness and ultimately the SBA will determine the amount forgiven.

What can I do now?

We do suggest you open a separate bank account and transfer the funds to this account.  When you have to make one of the approved payments transfer the exact amount to your regular operating account and pay the bill.

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IRx Accounting has posted a number of recent blog article regarding the CARES Act.  This important piece of legislation provides relief and assistance in various forms to Small Businesses in dealing with the global coroanvirus pandemic.

This purpose of this blog post is to provide a summary of the links to the previous blog posts for your easy reference and navigation.

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