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Revised January, 2010 CONFIDENTIAL AND PROPRIETARY - page 7 / 31





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Liability Coverage

Please refer to your Pharmacy Network Agreement with Walgreens Health Initiatives for specific insurance requirements.

Prescription Medication Fraud, Waste, and Abuse

Walgreens Health Initiatives takes health care fraud, waste, and abuse (FWA) seriously. CMS published a final rule entitled, "Revisions to the Medicare Advantage and Part D Prescription Drug Contract Determinations, Appeals, and Intermediate Sanctions Processes,” FR Doc. 07-5946 (72 FR 68700 through 68741) in December 5, 2007. Pharmacy training requirements became effective January 1, 2009 and must be completed by December 31, 2009. Pharmacy must attest to completing such FWA training and must reaffirm and attest to this training annually thereafter.

It is the responsibility of the pharmacy to ensure appropriate FWA training is provided to its employees, including managers and directors, using a FWA training program which meets the requirements of CMS and Walgreens Health Initiatives. It is also the responsibility of the pharmacy to maintain a log of pharmacy personnel who have received FWA training and a copy of FWA training materials, all of which are available to WHI for review upon request. Additionally, the network pharmacy must provide an attestation to the fact that all its employees, including managers and directors, receive such training at the time of hire and annually thereafter.

Guidance on Medicare Part D FWA can be obtained from CMS' Chapter 9 - Part D Program to Control Fraud, Waste and Abuse of the Prescription Drug Benefit Manual. This chapter provides both interpretive rules and guidelines on how to implement the regulatory requirements under 42 C.F.R. § 423.504(b)(4)(vi)(H) to have in place a comprehensive fraud and abuse plan to detect, correct and prevent FWA as an element of a compliance plan. Additionally, this chapter outlines CMS’ guidelines for operational issues such as handling complaints, and coordinating with CMS and law enforcement.

Twenty-four hour Toll Free Hotline: Email:

1 (800) 666-5677 Compliance@walgreens.com

Fax Information to WHS Compliance: 1 (847) 964-6950


Walgreens Health Services Attn: WHS Compliance 1415 Lake Cook Road, MS L346 Deerfield, IL 60015

How to Report Potential Fraud, Abuse, or Suspicious Activity

If you suspect fraud, abuse, or suspicious activity has occurred, is occurring, or will occur, please report it immediately through any of the following ways:

In addition to the above reporting resources you may report potential Medicare Part D drug violations to the:

Walgreens Health Initiatives – Pharmacy Manual


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