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Effective Jan. 1, 2009, plan sponsors must not only monitor their own internal processes, but those of their first-tier, downstream and related entities, such as agents and brokers, PBMs, network pharmacies and physicians. They must educate and train all such entities that interact with beneficaries, with plan sponsors ultimately responsible for any problems CMS finds during audits, regardless of whether the problems stem directly from the sponsor’s own actions or those of one of their downstream entities.

Now is the time for sponsors to study their contracts with downstream entities to identify and reduce noncompliance. There are numerous requirements that must be met and steps that plan sponsors must take to escape CMS fines and penalties in the days ahead.

Hear experts, Susan Hayes of Pharmacy Outcomes Specialists and Steven Arbaugh of ATTAC Consulting Group discuss the details of urgent new compliance challenges Part D plans face . . . and learn what practical steps you can take to monitor and audit your downstream entities to identify and eliminate fraud and abuse for which you will be held responsible.   
 
Topics covered include:

• Understanding new requirements for plan sponsors to monitor, educate, and train their downstream entities
• Effective strategies for contracting with downstream entities
• Recommended ways you should analyze claims data from physicians, PBMs, and pharmacies
• Successful tips and tactics for auditing your downstream entities
• How to develop effective data-mining methods that will flush out prescriber and pharmacy fraud and abuse
• What CMS expects plans to voluntarily self report

Speakers

SUSAN HAYES is a principal and founder of Pharmacy Outcome Solutions, a health care consulting firm, where she is responsible for the strategic direction of the firm and specific sales, proposal, product pricing, and development.  She is a lead project manager for the firm's audit and outsourcing clients, which include Rockford Health Plans, major Blue Cross and Blue Shield organizations, and Northwest Airlines.  Previously, Hayes was vice president of marketing for Systemed Pharmacy, Inc and vice president, marketing of Walgreens Healthcare Plus.  In both positions, she was responsible for the strategic development of the target market and product mix for PBMs, growing retail and mail-service revenues and enhancing overall client retention.  For five years prior to Walgreen Co., Hayes was the national practice leader for William M. Mercer, Inc., specializing in prescription drug auditing and bid procurement amounting to more than $1 million annually in revenue. Clients included Arthur Andersen & Co., Exxon USA., Ameritech, Sara Lee Corporation, the Marmon Group and Uniroyal.

STEVE ARBAUGH is a principal with ATTAC Consulting Group, LLC (ACG), where he is responsible for guiding client strategy and developing a broad range of managed care programs and operations, as well as leadership on development, implementation and operation of Medicare Advantage and Medicare Part D benefit programs; fraud, waste and abuse control programs; and compliance monitoring systems. Over his career, he has served in senior executive roles and operations posts, including holding the positions of CEO and chief operating officer with a number of health plans and insurers. He has previously worked with companies such as United Healthcare, Methodist Health Plan, (Texas), First Care (Texas) and Care Choices Health Plans (Michigan). Prior to joining ATTAC Consulting Group, Arbaugh was executive vice president with a national consulting firm specializing in Medicare Advantage and Part D programs. Before that, he was a long-term member of the consulting team at The Pace Group.

Moderator: Barbra Golub, JD, managing editor of Medicare Part D Compliance News.

Designed Especially For

Part D product managers, compliance officers, internal auditors, legal counsel, government-relations managers, financial executives, program managers, provider-relations managers, and others with Part D responsibilities at:

• Medicare Prescription Drug Plans (PDPs)
• Medicare Advantage plans
• Pharmaceutical companies
• Pharmacy benefit management companies
• Law and consulting firms

Written Materials