Review your results below to discover risks your pharmacy may experience and how to address them.

 

1. Are all employees at your facility completing FWA Prevention training annually?

You answered: 

  • Yes- Fantastic!
  • No- Add this to your “To-do List” as this is a federal requirement if you bill Medicare and/or State Health Care Programs.


2. If you are a pharmacy, are OIG-SAM verifications conducted on all employees (W-2, 1099) monthly?

You answered: 

  • Yes- Awesome!
  • No- Start now! This is a mandatory requirement to bill Medicare and/or State Health Care Programs.


3. If you are a pharmacy, are OIG-SAM verifications conducted on all Business Associates and Vendors monthly?

You answered: 

  • Yes- Great!
  • No- Start doing this immediately! This is a mandatory requirement to bill Medicare and State Health Care Programs.


4. Does your facility retain OIG-SAM reports for 10 years?

You answered: 

  • Yes- You’re on top of things!
  • No- Time for more paperwork! If you don’t, Medicare/Medicaid can revoke any funds for the periods you do not have documentation.


5. Do employees of your facility know how to report suspected Fraud, Waste or Abuse?

You answered:

  • Yes- Perfect- Let’s hope they don’t need to!
  • No- This is a simple thing  to work into your training.


6. Does your facility have an OIG hotline poster posted within the facility?

You answered: 

  • Yes- Good!
  • No- You can download this from our Compliance Portal if you are a client.


7. In the past year have all employees and owners completed a Conflict of Interest Certification?

You answered: 

  • Yes- Thank Goodness! It's best to have these signed!
  • No- Consult your attorney and require your employees to read and sign. Keep a copy in their personnel folder.

 

8. If your patient's prescription is rejected by code "569", is the notification to the patient being documented?

You answered:

  • Yes- Whew! This is something a lot of people miss- Good Job!
  • No- This is easy to work into your training.


9. Are you completing Medicare Part D annual attestations?

You answered: 

  • Yes- Great make sure you do both HIPAA and FWA trainings! 
  • No- You are at risk to lose all of your Part D reimbursements.

 

10. If a member of your staff is found to be on the Exclusion List even after the additional verification- do you terminate this employee?

You answered:

  • Yes- Hopefully this never happens.
  • No-It’s necessary to avoid fines, penalties, and termination of your PTAN.