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Regulations & Laws

Fraud, Waste, and Abuse

FWA

A category of compliance training and controls required of pharmacies that participate in Medicare Part D, aimed at preventing improper billing, kickbacks, and misuse of program funds.

In depth

CMS requires Part D sponsors - and the pharmacies in their networks - to maintain an effective compliance program that includes FWA training. “Fraud” is intentional deception for gain, “waste” is overuse or careless use of resources, and “abuse” is practices inconsistent with sound fiscal or clinical norms. Practical pharmacy controls include annual FWA and general compliance training, exclusion screening, accurate claims and recordkeeping, and a way for staff to report concerns.

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