Preventing Fraud, Waste and Abuse Training Program

CMS released the final guidance in April 2006 of the Medicare Part D – Prescription Drug Benefit, for compliance guidance to all Medicare Part D Sponsors titled “CMS Prescription Drug Benefit Manual, Chapter 9 – Part D Program to Control Fraud, Waste and Abuse”. Section 50.2.3 of the Manual dictates that all Sponsors and their “downstream entities”, which include pharmacy and healthcare workforce members engaged in delivering any Medicare services, receive general and specialized training to prevent fraud, waste and abuse.

Authors for this online program are Don L. Bell, General Counsel/Vice President, Legal Affairs and Mary Ellen Kleiman, Assoc. General Counsel, both of the National Association of Chain Drug Stores. Contributing as course reviewers:

• NACDS Fraud, Waste and Abuse Workgroup
• Gorman Health Group, LLC
• John Bettac, Supervisory Special Agent, HHS OIG Office of Investigations
• Sharon L.G. Donnelly, AHFI, CFE, Senior Manager, Data Intelligence Unit Audit, Risk Management, and Corporate Compliance, Blue Cross/Blue Shield of Florida
• Donna Hoffman, Senior Manager, Corporate Compliance, Health Care Service Corporation

The program has been designed to help organizations ensure that employees are in compliance with FWA related laws and CMS issued compliance requirements. After receiving this training, it is expected that pharmacy and healthcare professionals will be able to:

• Understand obligations for identifying FWA
• Identify, prevent, and report FWA
• Recognize the penalties for violating FWA laws and guidelines
• Understand protections afforded employees when reporting suspected FWA

For more information about Fraud, Waste and Abuse requirements please go to http://www.mintz.com/newsletter/2006/Health-Alert-Final-CMS-Fraud-4-28-06/