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Fraud, Wast and Abuse Guidance for Medicare Part D

Client Alert | 1 min read | 02.24.06

The Medicare Prescription Drug Benefit – Part D – imposes a legal requirement on Part D contractors to adopt a fraud, waste, and abuse (“FWA”) plan. On February 8, 2006, CMS issued a sixty-three page draft of FWA guidance to be contained in Chapter 9 of CMS’ Prescription Drug Benefit Manual, significantly enhancing the agency’s initial eight-page draft issued in June 2005. On February 23, 2006, the Health Care practice group at Crowell & Moring LLP conducted an online webinar in response to the new draft requirements. Crowell & Moring's webcast, aimed to quickly arm Plan Sponsors as well as downstream participants in the Part D benefit with what they need to know about the new requirements, discussed how to augment compliance and internal audit resources, develop new employee and subcontractor training programs, adopt scores of new "required" written policies and procedures, draft new contract clauses for Part D subcontractors, and enhance internal procedures for handling internal and external reports of potential Sponsor, provider, and beneficiary misconduct. To view a copy of the presentation, please click here.

Insights

Client Alert | 2 min read | 07.15.26

CMMC Phase II Suspension Requires Reconsideration of Such Requirements in Solicitations

As discussed in more detail here, the U.S. Department of War (DoW) recently issued a memorandum (Memo 26-P-1023, dated July 13, 2026) directing the immediate suspension of Cybersecurity Maturity Model Certification (CMMC) Phase II requirements (Level I and II self assessments are still permitted). Significantly, the memo directs that “all pending and future CMMC implementation milestones across DoW solicitations and contracts are held in abeyance until further notice.” Moreover, the DoW issued a memorandum on implementing these requirements (available here), directing agencies to issue amendments removing CMMC Level 2 and 3 requirements from active solicitations “as soon as practicable.” Contractors should monitor the government’s compliance with this requirement and should be prepared, if needed, to file a bid protest to protect their rights....