Medicare Part D Fraud, Waste and Abuse Compliance

CMS Clarifies Medicare Part D Fraud, Waste and Abuse Training Requirements
The Centers for Medicare & Medicaid Services (CMS) has provided additional information pertaining to the Fraud, Waste and Abuse training requirements required for all Medicare Part D providers due to multiple inquiries from Part D Sponsors and their first tier, downstream and related entities (including pharmacies and pharmacy staff).

The clarification by CMS identifies the following:

• The Part D plan sponsor is responsible for providing appropriate fraud, waste and abuse training to all healthcare providers it has a contractual relationship with (including pharmacies).
• The mandatory fraud, waste and abuse training requirement becomes effective January 1, 2009.
• Training must be completed yearly and can be completed in the calendar year to meet the requirement (January 1 to December 31). Training completed prior to January 1 does not meet the requirement for the next calendar year.
• All individuals employed by the pharmacy who have any interaction with a Part D beneficiary must receive the mandatory training (pharmacists, pharmacy technicians, cashiers, drivers etc..
• A record of all fraud, waste and abuse training must be maintained for a minimum of 10 years.
• First tier, downstream and related entities (including pharmacies) should NOT develp their own training. CMS has indicated that they are working with some organizations to provide a training program that will meet their requirements.

Providers can view additional guidance pertaining to CMS’s requirements for a comprehensive program to prevent and detect fraud, waste and abuse in the prescription drug program in Chapter 9 of the Medicare Prescription Drug Benefit Manual.

TPA provides online education opportunities for Fraud, Waste and Abuse continuing education.