Medicare Part D Fraud, Waste and Abuse attestation is one of the easiest Federal requirements to comply with. This program was implemented in 2006 and every pharmacy has had to certify each year since.
The 5 key points that each pharmacy must do to comply with this Federal mandate are:
1. Have a Fraud, Waste and Abuse (FWA) program
2. All employees (includes front end) must have annual FWA training
- The training can consist of lecture, training session and computer based training
3. Maintain training documentation
- Training Logs
- Training Certificates
4. Complete annual OIG Exclusion Verification for all employees, 1099 employees, wholesalers and vendors
- http://exclusions.oig.hhs.gov/
- The new Express Script contract states the verification check must be accomplished monthly. (Personally this is overkill)
- If an individual or entity appears on the Exclusion list, you must terminate the employee or vendor immediately
5. Complete annual Conflict of Interest certifications for owners, professional staff and managers. The remainder of the employees are optional
Every Medicare Part D insurance company must contact their participating pharmacies annually to validate compliance. This process is the attestation.
The insurance companies change their reporting requirements annually and there is no standard between them. Please read each one carefully because they all ask for additional information.
Failure to comply with the attestation will lead to the pharmacy either losing their reimbursements or the pharmacy being dropped as a Part D participant.
In addition, FWA is a Medicare Part B requirement. FWA compliance is verified during an accreditation survey and CMS On-Site Inspections.
If the pharmacy is exempt from accreditation, this requirement is still mandatory.
I am not aware of any statute that permits a buying group or a PSAO to certify compliance for their member pharmacies.
If you have would like to learn more about our FWA program please feel free to contact Jenny Schell at jenny@rjhedges.com
