Snapshots vs. streaming: why true pharmacy payment integrity needs both audits and continuous monitoring

Oversight requires more than one lens

Pharmacy benefit manager (PBM) oversight is often treated as a single discipline. In practice, it is two complementary functions that serve entirely different purposes: episodic audits and continuous monitoring. Each provides a different lens on financial accuracy, operational integrity, and risk exposure.

Audits give payers a backward-looking, documentable record of what happened. Continuous monitoring gives them real-time assurance of what is happening now. When these two lenses work together, payers gain clarity that neither can provide alone.

The role of episodic (recovery) audits: governance, compliance, and after-the-fact accountability

Episodic audits play a critical role in pharmacy governance. They provide an objective record of past performance, confirm whether pricing and benefit rules were followed, and deliver documented recoveries that demonstrate contractual and compliance oversight.

These reviews answer essential questions:
What went wrong? How much was overpaid? How much can we recover? What does this tell us about vendor performance?

Common findings include coordination of benefits errors, missed discounts, incorrect dispensing fees, and rebate or pricing discrepancies tied to specific contractual guarantees. These audits create transparency, strengthen fiduciary accountability, and supply an auditable trail for CMS, OIG, boards, and internal compliance teams.

The limits of episodic audits

Audits are indispensable, but they have inherent limitations:

• Time lag: Errors may persist for months before detection.

• Incomplete recovery: Negotiations rarely recoup the full value of overpaid dollars.

• Temporary fixes: Issues identified during an audit often reappear because the underlying cause was never actively monitored.

• Narrow scope: Audits tend to sample claims or focus on defined contractual terms rather than the full operational environment.

Audits tell you what happened. They cannot verify whether improvements stick or whether new sources of leakage are emerging.

Continuous monitoring: real-time integrity, cost avoidance, and sustained confidence

Continuous monitoring shifts oversight from periodic review to ongoing control. Instead of evaluating prior-year performance, it evaluates every claim in real time, comparing adjudication outcomes to pricing rules, benefit design, and operational logic.

Where audits ask what happened, continuous monitoring asks whether everything working today is working as intended.

Continuous monitoring can:

• Detect NADAC or other pricing discrepancies before reimbursement

• Catch duplicate therapy or early refill issues as they occur

• Validate coordination of benefits before primary payment goes out

• Flag high-cost claims for verification prior to payment

• Identify drift, misconfiguration, or changes in behavior immediately when they occur

This approach protects every claim and every dollar at the moment of adjudication, preventing leakage instead of documenting it after the fact.

What continuous monitoring adds that audits cannot

Real-time monitoring does more than detect errors. It provides visibility into:

• Whether issues identified in past audits reappear

• Whether benefit updates, plan changes, or price file refreshes introduce new errors

• Whether specific pharmacies or claim patterns behave outside expected norms

• Whether operational fixes implemented after an audit are functioning as designed

Continuous monitoring becomes the source of truth that confirms whether the system is behaving as intended every day, not just every audit cycle.

How the two approaches reinforce each other

Episodic audits and continuous monitoring are often described as separate strategies. In reality, the strongest oversight programs use them together.

• Audits define historical performance, establish accountability, and quantify past leakage.

• Continuous monitoring validates that corrections are working and ensures new issues are caught long before the next audit.

• Audit insights strengthen the monitoring framework.

• Monitoring insights reduce the volume and severity of future audit findings.

Together, they create a closed-loop integrity model: one that reveals what happened, controls what is happening, and prevents what could happen next.

What this means for health plans, employers, and partners

For health plans

Using both tools together strengthens compliance posture, improves vendor alignment, and reduces total pharmacy spend by addressing both past leakage and real-time accuracy. It gives plans a full picture: historical accountability and continuous assurance.

For self-funded employers

Continuous monitoring transforms pharmacy oversight from a once-a-year review to an everyday control. It protects budgets in real time and creates a clear, data-driven narrative for renewal discussions.

For channel partners

Providing both retrospective and real-time oversight positions partners as stewards of integrity. It reduces downstream rework, strengthens trust with clients, and differentiates your offering in a market that increasingly expects transparent, data-backed oversight.

The takeaway

Audits provide the snapshot. Continuous monitoring provides the stream. One confirms where you have been. The other ensures you are headed where you intend to go.

In a pharmacy environment defined by rising costs, complex benefit designs, and accelerating therapeutic innovation, relying on audits alone leaves too much to chance. The future of pharmacy payment integrity belongs to organizations that combine historical accountability with real-time control to protect every dollar, past and future.