OptumRx Contracted Network Provider Pharmacy Fraud, Waste and Abuse (FWA) and General Compliance Training Attestation
OptumRx Contracted Network Provider Pharmacies are required to electronically sign this attestation to satisfy mandatory compliance requirements related to guidance from the Centers for Medicare & Medicaid Services (CMS). CMS has set forth expressed guidance within the Federal Register at Title 42 of the Code of Federal Regulations (CFR), Parts 422 and 423 and other agency guidance requiring Medicare Advantage and Prescription Drug Plan sponsors, or their delegates, first tier, related, and down-stream (FDR) entities to demonstrate compliance with the following:
1. Contracted Network Provider Pharmacy hereby verifies and certifies that it has reviewed and conducted satisfactory annual Fraud, Waste and Abuse (FWA) and general compliance training programs or has utilized the training program provided by CMS and also has provided staff with links to our client sponsor Code of Conduct policies which is located online at https://www.optumrx.com/RxsolHcpWeb/fraudabuse/fraudwasteabuse.html with pharmacy staff. In addition, Contracted Network Provider Pharmacy hereby verifies and certifies that it has not been excluded from participation in federal health care programs by checking its status in Federal programs exclusion lists maintained by the General Services Administration (GSA) and the Department of Health and Human Services Office of Inspector General (HHS-OIG). In turn, Pharmacy has reviewed the Health & Human Services (HHS) Office of Inspector General (OIG) and General Services Administration's (GSA) lists prior to hire/contracting and monthly thereafter for its current employees/contractors, health professionals, or vendors that work on MA, Part D, Medicare-Medicaid Plans (MMP), or Medicaid programs to ensure that none are excluded from participating in these programs. This information is available at the following sites:
- Office of Inspector General's (OIG) List of Excluded Individuals/Entities (LEIE) - https://oig.hhs.gov/
- General Services Administration (GSA) Excluded Parties List System (EPLS) - https://www.sam.gov/
- General Services Administration (GSA) System for Award Management (SAM) - https://www.sam.gov/
2. Contracted Network Provider Pharmacy hereby verifies and certifies that attendance logs, materials, training documents, and other evidence in support of compliance with item "1." above is and shall continue to be made available by Network Contracting Pharmacy for inspection and review by OptumRx or auditor during on-site audits or other review processes. This inspection may also be conducted by the Payer(s) and other federal regulatory agencies as outlined in 42 CFR 422.504(e) and 422.503(d)(2)).
3. Contracted Network Provider Pharmacy hereby verifies that clearly defined processes and criteria to evaluate and categorize all vendors with which you contract to determine if they meet the definition of an FDR are available. Documentation of your process or procedures to audit and monitor your downstream entities for compliance with CMS requirements will be made available upon request.
- NOTE: CMS requires records demonstrating compliance with these requirements be maintained for ten (10) years. This includes all individuals trained be listed along with the date the FWA and general compliance training information is provided/completed, and date of Department of Health and Human Services (HHS)-Office of Inspector General(OIG)/General Services Administration's (GSA) monitoring review. You can download a form for this purpose and keep on file for future audit purposes. It is not necessary to send this to OptumRx but it must be made available immediately upon request in the event of an audit. In our experience, auditors expect us to provide this information the same day it is requested and we greatly appreciate your cooperation.
Network Pharmacy Agreement
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