Medicare Information for Pharmacists - FWA Training

8/30/09 - Update on the Medicare Parts C and D Fraud, Waste and Abuse Training Requirements…

CMS has received numerous inquiries regarding Fraud, Waste and Abuse (FWA) training requirements for pharmacies and other first tier, downstream and related entities. Due to the potential burden on all parties, CMS strongly encourages Medicare Advantage Organizations (MAOs) and Prescription Drug Plan (PDP) Sponsors to work with their contract entities to provide standardized training. Accordingly, today we released the attached memorandum to provide guidance and clarification to MAO and PDP sponsors concerning the implementation of FWA training.

We clarify that in order to meet the FWA training requirement for first tier, downstream, and related entities, MAOs and PDP Sponsors may either provide the training directly or provide appropriate training materials to these delegated and contracted entities. The MAO or PDP sponsor is accountable for ensuring that materials have been provided to all entities. Topics that should be addressed in a FWA training program include, but are not limited to:

• Laws and regulations related to MA and Part D fraud, waste and abuse (i.e., False Claims Act, Anti-Kickback statute, HIPAA, etc)
• Obligations of the first tier downstream, and related entities to have appropriate policies and procedures to address fraud, waste, and abuse
• Process for reporting to the MAO or PDP sponsor suspected fraud, waste and abuse in first tier, downstream, and related entities
• Protections for employees of first tier, downstream, and related entities who report suspected fraud, waste and abuse
• Types of fraud, waste and abuse that can occur in first tier, downstream, and related entities

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