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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 | 4 min read | 07.22.26

FCPA and National Security Objectives Align: DOJ Announces First Settlement Related to Bribes That Benefited Mexican Cartels

On July 17, 2026, the United States Department of Justice (DOJ) announced that it had entered into a Deferred Prosecution Agreement (DPA) with The Scoular Company (Scoular), an agricultural supply chain company based in Omaha, Nebraska, to resolve allegations that Scoular relied on customs brokers to bribe Mexican government officials to allow Scoular goods to pass customs inspections and be delivered to Mexico from the United States. As part of its resolution, Scoular agreed to pay a $9,769,521 criminal penalty and forfeit an additional $414,351. Scoular also committed to continue cooperating with DOJ on any ongoing or future criminal investigations, implement a compliance and ethics program designed to prevent and detect violations of the Foreign Corrupt Practices Act (FCPA), and periodically report to DOJ on remediation and implementation of compliance measures throughout the term of the DPA....