Review of Sterling Life Insurance Company's Internal Controls To Guard against Fraud, Waste, and Abuse for the Medicare Part D Program

Sterling Life Insurance Company (Sterling) had several internal control weaknesses that compromised its ability to detect, correct and prevent fraud, waste and abuse in the Part D program during the period of July 1, 2007, through June 30, 2009. Specifically, Sterling did not (1) ensure that its employees completed compliance training, (2) require its contracted entities to provide compliance training to their employees, (3) perform monitoring activities of its contracted entities, or (4) have a formal compliance committee. As a result, Sterling compromised its ability to detect, correct, and prevent fraud, waste and abuse in the Part D program and increased the risk that improper payments may have occurred.