Pharmacy Compliance Guide

Attestations & Certifications

Every fall we hear the PBMs sending out requests for Attestations for Fraud, Waste and Abuse and HIPAA Compliance. Why do they all keep asking for the same information?

When Medicare Part D came into play, the Pharmacy Benefit Managers were given the regulatory authority to manage the Medicare Part D program. Part of this program was ensuring pharmacies were properly training their staff. It initially started with annual:

• Fraud, Waste & Abuse Training,
• OIG Exclusion Verification, and
• HIPAA Compliance Training

Then each fall, everyone had to attest they accomplished these requirement for Medicare Part D. Unfortunately, a lot of pharmacies and organizations signed off of the attestations and really didn’t do it.

The a