issues of fraud, waste and abuse. Fraud, waste and abuse or collectively known as FWA are the three main issues in pharmacy that garnered considerable attention. The three crimes are considered as connected terms because they tend to go hand-in-hand or they are related. It is of vital importance to prevent and put a halt in the prevalence and pervasiveness of any kind of fraud, waste and abuse in the world of pharmacy. There are various mitigating and initiatives applied to fight against these crimes. Compliance Processes and Training Compliance Program
The Centers of Medicare and Medicaid Services or the CMS of the Department of Health and Human Services released a comprehensive report and guidelines of compliance requirements and recommendations in 2006. This serves as a complete guide for pharmaceutical companies for their compliance and also a mean of preventing fraud, waste and abuse in the company. The guidelines released by the CMS apply to the Medicare part D plan sponsors and to other community-based pharmacies that contract with sponsors. The Code of Ethics of a company is the cornerstone of every compliance program.
The compliance program of every company should be embedded in the company’s Code of Ethics. The Code of Ethics should state the legal and ethical obligations of the employees in relation to fraud, waste and abuse. Moreover, it should be in line with the different anti-fraud and abuse laws and statutes implemented. Another important part of the compliance program of a company is the compliance officer. The role of the compliance officer is very important in ensuring that the employees are adhering to the rules and guidelines set by the company as well as the federal authorities, laws and statutes.
Some of the tasks of a compliance officer are: • “Enforcing the Code of Ethics. • Developing, implementing and enforcing the program. • Reporting compliance incidents within the company. • Overseeing compliance training. • Developing and implementing a compliance reporting system. • Following up on all reports of alleged fraud and abuse. • Reporting potential fraud and abuse to the appropriate authorities. (Bell & Kleiman, 2010, n. p. ). Also, part of the duties of a compliance officer is to conduct internal audits to all of the company’s operations as well as to check on the provision of services and billing practices.
These are for the purpose of confirming the compliance program of the company ands to assess the weaknesses of the said program. FWA Training One of the essential parts of a compliance program is a comprehensive training in fraud, waste and abuse. The training aims to familiarize every employee about the different issues of fraud, waste and abuse in the company. It also educates you with the company’s compliance program and the obligations under the said program. The training will also teach you on how to spot and report cases and incidents of fraud, waste and abuse in the company.
In the training, your rights and privileges will also be explained to you if you report a potential fraud, waste and abuse case or incident. The training is a must requirement for big pharmaceutical companies under the Medicare Part D. The training of the employees can either be general o specialized. Specialized training set emphasis on different additional topics and issues for the employees who are involved in carryings out some provisions of services that are encompassed by the federal or state healthcare programs.
Some of these services are filing claims, dispensing drugs, billing-coding, sales and marketing of health care products and services. All of the cases of fraud, waste and abuse can be reported to the immediate supervisor, appropriate reporting department or to the federal authorities. The reports and cases will go through proper investigation that is composed of interview, documentary review and other appropriate methods that will help solving the case.
If the person is proven guilty of non-compliance and red-handed of acts of fraud, waste and abuse, this may lead to the proper and appropriate disciplinary action. The compliance officer may call the attention of the appropriate company officials to ensure actions in resolving the problem that may lead to re-training, demotion, reprimand, suspension and termination. If the case is serious, corrective actions maybe take to prevent future occurrences as well as calling the aid or notifying appropriate federal authorities.