On February 8, CMS released an updated, greatly expanded draft of its guidance for Part D prescription drug plan sponsors on the structure and focus of the compliance programs required under their contracts with CMS. The draft guidance constitutes an entire chapter in the Prescription Drug Benefit Manual. It may be downloaded at the CMS Web site.

The draft guidance assigns monitoring and auditing duties to Part D plans focused on activities of non-plan stakeholders similar to the program integrity work historically undertaken by Medicare contractors who process provider and supplier claims. The guidance also explains the oversight role of Medicare Drug Integrity Contractors (MEDICs) retained by CMS to review plan operations and coordinate Part D anti-fraud and abuse efforts. The guidance includes an overview of potential schemes and risk areas relevant to Part D plans themselves and to beneficiaries, pharmacies, prescribers and pharmaceutical manufacturers.

CMS is soliciting comments from all stakeholders through March 1, 2006. Comments should be submitted in word by e-mail to CMSpartD_FWA_Comments@cms.hhs.gov.

If you have questions or need assistance with your comments please contact:

Larri Short
202.775.5786 
short.larri@arentfox.com