What you need to know about CMS Part D: PART D Fraud, Waste, and Abuse Requirements
About Part D
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.
Part D plans are now obligated to have a FWA plan in place. The newly issued draft guidance contains new and onerous requirements. Plans must move quickly to adopt a FWA plan that complies with these requirements, all within available budgets and resources. The risks to plans that do not develop a comprehensive FWA plan are significant, including contract cancellation, penalties, and other financial and business consequences.
About This Webinar
The Health Care practice group at Crowell & Moring LLP is offering an online webinar on Thursday, February 23rd to quickly arm you with what you need to know about these new requirements. For those of you planning to listen in on CMS' February 22nd webcast on its draft FWA guidance – and we recommend that you do – our webinar will expand and comment upon, rather than summarize, the draft guidance.
A few of the initiatives you will need to plan for include augmenting compliance and internal audit resources, developing new training programs, adopting scores of new policies and procedures, drafting new contract clauses for Part D subcontractors, and enhancing internal procedures for handling reports of potential misconduct. There are also untold pitfalls related to working with CMS's Part D agents, the MEDIC contractors, that Part D contractors need to be aware of. Of importance, during the webinar we will identify those areas in the draft guidance that remain open issues, in case your organization wants to submit public comments to CMS before their March 1 deadline.
Crowell & Moring's Health Care group will be conducting this afternoon webinar to quickly arm you with what you need to know about these new requirements.