Medicare Prescription Drug Sponsors' Training To Prevent Fraud, Waste, and Abuse

Nearly all Part D network pharmacies received training to prevent fraud, waste, and abuse in 2009; however, not all sponsors documented the training. With a few exceptions, the content and source of most training materials reflected CMS guidance. However, more than a third of the training materials failed to include information on the Health Insurance Portability and Accountability Act, and more than half of the materials were developed by pharmacies' corporate offices, despite CMS guidance stating that pharmacies should not develop their own materials.

We also found that some sponsors were unable to determine the extent to which training was effective in preventing fraud, waste, and abuse. Forty-one percent of sponsors did not assess the training's effectiveness.

As a condition for contracting with CMS to offer Part D benefits, sponsors must have plans that help them comply with Federal regulations and prevent fraud, waste, and abuse. Among other elements, plans must include effective annual training and education on fraud, waste, and abuse for their network pharmacies.

We recommend that CMS reiterate to sponsors their responsibilities as the entities accountable for network pharmacies' training on fraud, waste, and abuse. We also recommend that CMS use its monitoring authority to determine sponsors' compliance with fraud, waste, and abuse training requirements. Finally, we recommend that CMS ensure that sponsors are providing training that is effective in preventing, detecting, and responding to fraud, waste, and abuse. For example, CMS could develop tools for sponsors to use in assessing the training's effectiveness or provide a forum in which sponsors can share best practices. CMS concurred with all of our recommendations.