January 8, 2007
By Tom Bixby*
Last week the Department of Health and Human Services' Office of Inspector General (OIG) released a report of the OIG's review of all stand-alone Prescription Drug Plan (PDP) Sponsors' compliance plans, including the Sponsors' Fraud, Waste, and Abuse (FWA) programs. The report concluded that 72 of 79 PDP Sponsors (91%) failed to address all CMS compliance plan requirements and many plans that addressed CMS requirements "did not contain detailed information about those requirements." The OIG reviewed compliance plans in place in January 2006, the first month of the Part D program.
The OIG report recommends that CMS "ensure that sponsors' compliance plans address all requirements presented in [Chapter 9 of the Prescription Drug Benefit] manual," and to "encourage sponsors to provide sufficient detail in their compliance plans to clearly demonstrate how sponsors are actually implementing the compliance plan requirements."
The report, entitled "Prescription Drug Plan Sponsors' Compliance Plans," is posted at http://oig.hhs.gov/oei/reports/oei-03-06-00100.pdf.
We would like to thank Tom Bixby of Neal, Gerber & Eisenberg LLP (Chicago, IL) for providing this email alert.