2018 340B reform: 2018 Medicare Annual Payment Rules finalized for outpatient hospital departments.


IOD practices’ Fraud, Waste and Abuse Training requirement

Groups with an in-office dispensing program are required to have dispensary employees complete and attest to an annual Fraud, Waste and Abuse Training. If not yet completed, make sure to do so by the end of the year. UroGPO will be glad to assist practices that have not yet updated their NCPDP and Third Party Station profiles with their attestation requirements.

Any entity that dispenses medications to Medicare Part D patients, that is contracted with Prescription Benefit Managers (PBMs), is required to train all dispensary employees on Fraud, Waste and Abuse and General Compliance. Each dispensary employee must complete the training and the practice must attest that all employees are in compliance.

You can meet these requirements in one of two ways.

  • First, have all dispensary employees (techs, billers, dispensing physicians, purchaser, manager, etc. – anyone who is part of the dispensary process who may be able to detect FWA) go online via the CMS Medicare Learning Network (MLN), take both the FWA & General Compliance courses and produce the certificates of completion at the end of each program.
  • Alternatively, each dispensary employee can attest to having read and understood the material by simply creating a one-page document on your practice letterhead with a statement indicating that “the below listed employees attest to having completed the CMS Fraud, Waste and Abuse and General Compliance programs.” List the employee names on the letter and have them sign and date next to their printed names. This document will serve as your annual attestation. This training is required before you begin dispensing, as well as annually.