Every company wants to operate free from fraud, waste, and abuse (FWA). It’s good for business. So, try to think of that as the silver lining to the fact that your pharmacy is required by CMS, and many states, to have a formal fraud, waste, and abuse compliance program.

The Affordable Care Act spelled out seven elements you need in your fraud, waste, and abuse program:

  1. Written policies, procedures, and standards of conduct
  2. A designated compliance officer and compliance committee, with high level oversight
  3. Effective employee training and education
  4. Effective lines of communication within your company
  5. Well-publicized disciplinary standards
  6. An effective system for routine monitoring, auditing, and identification of compliance risks
  7. Procedures for prompt response to compliance issue

CMS enforcement efforts will primarily be looking for the completion and documentation of:

  1. Appropriate claims data
  2. Conflict of interest attestations
  3. Annual employee fraud, waste, and abuse training
  4. Monthly checks for employees on the OIG (Office of Inspector General) and SAMS (System for Award Management) exclusion lists.

You can read more about FWA compliance program guidelines on the CMS website. This PDF document will help you create your fraud, waste and abuse program or make sure that a program you purchase is complete.

For more information about Fraud, Waste and Abuse and other pharmacy compliance solutions for your pharmacy, call PRS at 1-800-338-3688 and speak with one of the Specialists. Please visit the Blog for additional posts on compliance issues and what you need to know as a pharmacy owner.