Catamaran 2014 Fraud Waste and Abuse (FWA) Frequently Asked Questions (FAQs) Where can I find FWA training materials? Catamaran has provided the CMS training materials on our website at www.catamaranrx.com/Providers or materials may be obtained by visiting CMS.GOV at the web address below. http://www.cms.gov/Outreach-and-Education/Medicare-Learning-NetworkMLN/MLNProducts/ProviderCompliance.html - click on the link, “Medicare Parts C and D Fraud, Waste, and Abuse Training and Medicare Parts C and D General Compliance Training”. Which employees in my pharmacy need to complete the training? Based on Chapter 9 and 21 from CMS (50.2.1) all FDRs (First-Tier and Downstream or Related entities), Governing body, managers, employees, and other individuals working in the Medicare program must complete the training. For network pharmacy providers this typically requires the pharmacy train all pharmacy staff and personnel which could be a part of the dispensing of pharmacy services and maintain appropriate training or oversight of any other contracted vendor/personnel/entity (e.g. temporary pharmacy staff). If my pharmacy does not process or submit Medicare Part D prescriptions or claims, does my pharmacy still need to comply with this training? Yes, Fraud, Waste and Abuse (FWA) can be prevalent in any line of business (commercial or government funded) and therefore Catamaran requests compliance with this training and attestation. Additionally, Providers who are not eligible to participate in Medicare, Medicaid, and other federal health care programs are not eligible to participate in any of the Catamaran networks and therefore Catamaran requests all providers complete the training and attestation process. When is the deadline for submitting my FWA Attestation via the online survey? Please complete the FWA and Compliance training and online survey by 12/31/2014 to ensure your pharmacy is not negatively impacted by administrative actions taken by our Pharmacy Membership Evaluation Committee (PMEC) to include Corrective Action, Suspension, or Termination from the pharmacy network. 2014/2015 Compliance Training Attestation – Fact Sheet Catamaran 2014 Fraud Waste and Abuse (FWA) Frequently Asked Questions (FAQs) Do I still need to take this training if my pharmacy is deemed DMEPOS-accredited? No, network pharmacy providers who have met the FWA certification requirements through enrollment into the Medicare program or accreditation as a Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS providers) are deemed to have met the training and education requirements for Fraud, Waste and Abuse. Your pharmacy will need to complete the online survey to notify Catamaran that you are DMEPOS-accredited. You will be asked to provide your accreditation date. (Reference 42 C.F.R. §§ 422.503(b)(4)(vi)(C), 423.504(b)(4)(vi)(C).) If I belong to a PSAO (Pharmacy Service Administrate Organization) do I need to complete an online survey for my pharmacy? Your PSAO will attest on your behalf; however your requirements to maintain records of your training and provide that information to your PSAO is an important component of complete compliance for our Catamaran network. Please confirm with your PSAO for actions necessary. If my pharmacy does not process or submit Medicare Part D prescriptions or claims, does my pharmacy still need to comply with this training? Yes, Fraud, Waste and Abuse (FWA) can be prevalent in any line of business (commercial or government funded) and therefore Catamaran requests compliance with this training and attestation. Additionally, Providers who are not eligible to participate in Medicare, Medicaid, and other federal health care programs are not eligible to participate in any of the Catamaran networks and therefore Catamaran requests all providers complete the training and attestation process. Our pharmacy completed a FWA Attestation form related to another Plan Sponsor, PBM or entity. Can our pharmacy provide a fax to Catamaran instead of completing the online survey? No, for tracking purposes, Catamaran must receive your attestation via the online survey. If you have difficulty accessing the internet or issues completing the online survey, please contact [email protected] for assistance. 2014/2015 Compliance Training Attestation – Fact Sheet Catamaran 2014 Fraud Waste and Abuse (FWA) Frequently Asked Questions (FAQs) How long does my pharmacy need to maintain training records or proof of the completed attestation? Your pharmacy is required to maintain training logs and/or proof of the attestation (information should include information such as trainings, type and method, vendor and date and time and signoffs from the staff, FDRs or contractors) for a period of ten (10) years (or longer if specifically requested as part of a CMS or government requested audit). Can I use compliance and FWA training from a different Plan Sponsor, PBM, or Entity? Yes, only if the training materials meet the requirements set forth by CMS for both FWA and General Compliance (42 C.F.R. § 422.503(b)(4)(vi)(C) and § 423.504(b)(4)(vi)(C). 2014/2015 Compliance Training Attestation – Fact Sheet