When Medication Delays Lead to Patient Complaints
By Caroline Girardeau, PharmD, MBA, PMP, BCPS, and Kris Ravotti, RRT, RCP
Caroline Girardeau brings more than 30 years of pharmacy experience to her role as Program Director, Pharmacy and PCAB (Compounding Pharmacy) Accreditation. She combines clinical expertise with a passion for education and quality improvement to help pharmacies strengthen their practices and deliver safe, patient-centered care.
Kris Ravotti serves as a Clinical Compliance Educator for DMEPOS, Sleep, Pharmacy, and Dentistry Accreditation Programs at ACHC. Kris is a regular contributor to ACHC’s knowledge bank of FAQs and articles and develops audit tools and other materials to support providers on the path to continuing compliance.
Posted: November 9, 2026
Early each year, patients or caregivers contact ACHC about medications arriving late, or not at all, due to changes in prescription or medical benefit coverage.
ACHC takes these reports seriously and conducts thorough investigations. These patient concerns often signal noncompliance with one or more ACHC Standards.
Equally important, pharmacies should proactively communicate with patients when drug shipment delays are anticipated, and cooperate with accrediting organizations when delays culminate in a complaint investigation.
Common missteps
A common thread in our investigation research is that organizations start client/patient outreach prior to the next scheduled dose without enough time to find and mitigate lapses in benefit coverage or prior authorizations. Who suffers? Patients and their caregivers.
Without enough time to work through changes, clarify dual benefits, and/or seek prior authorizations with the client/patient and/or insurance company, therapy interruptions negatively impact patients' quality of life and safety.
Another common misstep is failing to recognize and identify when a patient or caregiver is communicating a concern that needs to be handled and channeled as a complaint or grievance.
When ACHC notifies a company that they are under investigation from a report concerning a negative patient experience or potential patient safety risk, it is important that the organization open a complaint or grievance at that time, if not done previously, and follow its own complaint policy and procedure.
Commonly cited deficiencies
Deficiencies that are often found in ACHC-accredited companies related to complaints include:
- DRX2-4A: Complaint policies were not followed. Personnel failed to document and report the complaint.
- DRX3-4B: Payor changes were not properly communicated to the patient or caregiver.
- DRX5-1B: Conversations with patients or caregivers were not documented.
- DRX5-2B: Untimely outreach prior to a needed refill.
- DRX5-2C: Care plans were not followed.
- DRX5-2G: Coordination of care did not occur or was not documented.
- DRX5-11B: Dose was not shipped/received in time for the next administration date.
If the accrediting organization (AO) finds that the complaint was substantiated with non-compliance in one or more standards, a plan of correction (POC) or corrective action plan (CAP) will be required. Additionally, the POC or CAP will require evidence that the corrections to address each deficiency are implemented within 30 days.
Cooperation with the AO is key.
As an AO, ACHC must comply with patient confidentiality and HIPAA requirements.
When investigating medication interruptions, ACHC may ask for call logs and patient progress notes within a specified timeframe. If documentation of patient medical records is requested, the organization should cooperate in sharing this information with ACHC.
If the organization states that all shared patient information will be redacted, the AO will conduct an unannounced survey at customer expense if standard non-compliance is cited. An in-person survey will allow us to review all the records that were previously requested and redacted or denied.
ACHC recognizes the complexity of navigating referrals, insurance, and care coordination. In the end, patients and caregivers have placed their trust in your organization, and in ACHC as the accreditor, to support the safe, and timely delivery of high-quality medications with appropriate safeguards and monitoring.
The calls to action are plentiful:
- Train your customer service team to proactively verify insurance benefit coverage with sufficient time to navigate coverage interruptions before a dose of medication is due.
- Recognize when there are barriers to care.
- Conservatively document a grievance or complaint early on if there is a suspicion of or confirmed medication delay(s).
- Follow your company’s grievance/complaint policy when a grievance/complaint is initiated.
For doses that will be due in January, it is imperative that companies ask about upcoming changes to benefit coverage in early December. A new calendar year is a particularly vulnerable time for both companies and patients to experience delays in timely dispensing.
These best practices will reduce the risk of medication interruptions, while sharpening your team’s recognition and responsiveness to clients/patients and caregivers who are experiencing suboptimal customer service and/or treatment.
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