Prepare for Part D audits

March 1, 2011

The impact and magnitude of expenditures should have made Part D an immediate enforcement priority for the Centers for Medicare and Medicaid Services

The Medicare Prescription Drug, Improvement, and Modernization Act of 2003 (MMA) established the Medicare Part D outpatient prescription drug benefit, which took effect on January 1, 2006. The impact and magnitude of expenditures should have made this an immediate enforcement priority for the Centers for Medicare and Medicaid Services (CMS) to ensure that the Part D program operates efficiently and is protected from fraud and abuse.

While CMS is responsible for oversight and implementation of safeguards to protect the integrity of the Part D benefit, oversight of Part D programs continued to evolve slowly-until now. An effective compliance plan helps sponsors protect the integrity of Medicare funds by preventing fraud, waste and abuse.

Since 2005, federal regulations have required sponsors to have compliance programs in place. Chapter 9 of CMS's Prescription Drug Benefit Manual ("Part D Program to Control Fraud, Waste and Abuse," available online), provides guidance on the elements outlined in regulatory requirements along with additional requirements and recommendations. It will be updated by CMS soon, making requirements more stringent.