The Centers for Medicare and Medicaid Services (CMS) on Tuesday, April 25, 2006, published in final form its guidance for Medicare Part D plan sponsors regarding their fraud, waste and abuse, and compliance responsibilities.
Although Chapter 9 of the Prescription Drug Benefits Manual, entitled "Part D Program to Control Fraud, Waste and Abuse," is directed to sponsors of Part D plans, it is relevant to all parties involved in the delivery of the Medicare prescription drug benefit, including subcontractors and pharmacies that manage or deliver prescription medications.
The guidance is available on CMS’ website at: http://www.cms.hhs.gov/PrescriptionDrugCovContra/Downloads/PDBManual_Chapter9_FWA.pdf.
CMS also is hosting a "Special Open Door Forum" on the final guidance on Tuesday, May 2, 2006, at 2 p.m. EST. The call-in number for the open door forum is 1-800-837-1935, and the Conference ID number is 8330971.
McDermott Will & Emery lawyers are reviewing CMS’ guidance and will issue a detailed On The Subject in the near future.