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CMS has already begun auditing both large and small Part D plans. The time has come for all plans to pay close attention to CMS’s recent activity on enforcement and compliance, testing their current performance and planning for compliance challenges for the rest of 2007 and 2008. What are the chief Part D compliance challenges ahead that may present your greatest risks? CMS is trying to finish up enrollment, direct and indirect reimbursement and Prescription Drug Event (PDE) transaction reporting reconciliation, and it is very likely that these areas will become focal points of future audits. Moreover, plan reporting requirements for direct and indirect remuneration (DIR) will change for plan years 2007 and 2008, and plans need to be aware of exactly what needs to be reported.

Not only must plan sponsors monitor their own internal process, but those that delegate some of the Part D requirements to pharmacy benefit managers (PBMs), whether outside or in-house, must also monitor those entities. Plan sponsors will ultimately be responsible for any problems CMS finds during an audit, regardless of whether the problem stems directly from their own actions or those of a PBM.

Hear industry veterans Steven Arbaugh and Susan Roberts 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 prepare for inevitable CMS audits and aggressive government enforcement.  

Topics covered include:

• How to develop robust internal monitoring processes for Part D
• Strategies for PBM oversight — how to monitor and audit your Part D PBM
• Specific steps you should take today to prepare for financial and FWA audits
• How to deal with changed DIR reporting requirements for plan years 2007 and 2008
• How to build sound operational policies in areas that are likely to be the focus of CMS audits, such as Prescription Drug Event reconciliation

Speakers

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 providing 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 COO 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, Mr. 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.

SUSAN ROBERTS is director of the Government Programs Group with ATTAC Consulting Group, LLC (ACG), where she provides overall leadership to the division. She has more than 23 years of experience in executive and operational roles in government programs in the insurance and managed care industry, with initial involvement with private-sector Medicare products when they were TEFRA demonstration projects. Prior to joining ACG, Ms. Roberts was CEO of Tri-Centurion, a Medicare Program Integrity Contractor, which had as its primary mission identification and pursuit of fraud, waste and abuse in the Medicare Part A and B programs. She also previously held the role of senior vice president for business development for UnitedHealth Group’s Evercare Division, where she was responsible for market development and product launch for the nation’s largest institutional Special Needs Plan. Ms. Roberts also served as the executive officer in charge of Medicare and Medicaid programs for regional plans operated by Humana and Prudential Health Care.

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

Designed Especially For

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

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

*Please note that shipping of CDs and materials will begin within three weeks of the conference.

Written Materials