PSSNY's Fraud, Waste & Abuse Manual - It's More Than That!

DECEMBER 1, 2009: NYS pharmacies will be required to "certify" with the Office of the Medicaid Inspector General (OMIG) that they have a Fraud, Waste & Abuse program in place.

DECEMBER 31, 2009: All pharmacy employees MUST BE TRAINED in your pharmacy's Fraud, Waste & Abuse Policies & Procedures for both the Medicaid and Medicare programs. How do you train them in your Fraud, Waste & Abuse Policies & Procedures if you don't have them in writing? Even if you don't meet the monetary thresholds of $500,000 cumulative ownership (Medicaid) or $5 million cumulative ownership (Medicare Part D), the "training" requirement covers ALL pharmacies.

JANUARY, 1, 2010: All pharmacies in the Medicare program will need to have their Fraud, Waste & Abuse Policies & Procedures in place (those with $5 million in annual cumulative Medicare sales) and, you will have to be able to "prove" that all your employees have been trained in Your Fraud, Waste & Abuse Policies & Procedures no matter what your Medicare sales are.

PSSNY has developed a 199 page low-cost Fraud, Waste & Abuse manual that is much, much more. This manual (that comes on a CD in a WORD format) provides you with all of the following:

• A review of the Regulatory Environment and Essential Elements of a Compliance Program;
• Risk Assessment;
• Designation of a Compliance Officer;
• Education & Training;
• Disciplinary Guidelines;
• Monitoring & Auditing;
• Effective Communication;
• Response & Corrective Action
• Policy of Non-Intimidation & Non-Retaliation;
• Supplier & Quality Standards;
• OIG Advisory Opinions

The PSSNY Fraud, Waste & Abuse Manual also provides the most updated critical Sample Written Policies & Procedures, such as:

• Code of Conduct Policy
• Governing Body Policy
• Risk Assessment Policy
• Policy on Medicare & Medicaid Billing
• Fraud & Abuse Policy
• Procedures for Handling a Medicaid Audit
• Procedures for Handling a Medicare Audit
• Procedures for Handling a Criminal Investigation
• Records Retention Policy
• Antitrust Policy
• Employee Screening Policy
• Sales & Marketing Policy
• Compliance Program Reporting Form
• Non-Intimidation & Non-Retaliation Policy
• Self-Disclosure Policy
• HIPAA Compliance Policy (newly updated)
• Compliance Program Reporting Form

Need we say more? Order your copy today as this will be the next BIG OMIG AUDIT finding. PSSNY has a limited number of CD's that we will begin shipping on Monday, November16. To order your CD today, fill out the order form and fax (518) 464-0618 to PSSNY. Or, call the office at (800) 632-8822 and ask for Mary or Kristina to order your copy.