Kaplan Eduneering: Medicare Fraud, Waste and Abuse Training: Impact on Pharmacy Benefit Managers

To Whom Does the FWA Training Requirement Apply?

The scope of the training requirement is all Medicare Advantage programs. In terms of Part D, this includes Medicare Advantage Prescription Drug Plans (MAPD) and stand alone Prescription Drug Plans (PDP). For the balance of this whitepaper, the term Part D Sponsor will be used to represent both MAPDs and PDPs.

A first tier entity means any party that enters into a written arrangement, acceptable to CMS, with a Part D Sponsor or applicant to provide administrative services or health care services for a Medicare eligible individual under Part D. In terms of the Part D program, this would most commonly be a PBM who contracts with the Part D Sponsor.

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Medicare Fraud, Waste and Abuse Training: Impact on Pharmacy Benefit Managers

To Whom Does the FWA Training Requirement Apply?

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