Reminder About Fraud, Waste and Abuse Training
To comply with the CMS regulation stated below, we require all contracted network pharmacies to complete Compliance FWA training on behalf of our client PDP plans.
The regulation, 42 C.F.R. § 422.503(b)(4)(vi)(C) and § 423.504(b)(4)(vi)(C), states that Medicare Part D Plan Sponsors must establish and implement effective compliance training for the contracting entity's employees, chief executives or other senior administrators, managers, governing body members, and first tier, downstream and related entities. The training must occur at minimum annually and must be made a part of the orientation for a new employee, new first tier, downstream and related entities, and new appointments of a chief executive, manager, or governing body member. Under these regulations, pharmacies are classified as "downstream" entities.
As a contracted pharmacy with our Network, it is required that an authorized individual having responsibility for all employees who have been identified as being involved directly or indirectly with the administration or delivery of the Medicare Part D Prescription Drug Benefit, including pharmacists and pharmacy technicians, attest to the completion of this requirement.
Further, you should maintain on site appropriate training attendance logs and be able to provide this to us, upon request, for audit purposes. At a minimum, such logs must include the name and date of training, name of instructor and name and signature of each attendee.
The FWA training materials can be accessed online via the following links:
http://www.mhrx.com/2011/compliance/fraud_waste_and_abuse.aspx