Risk Assessments
The OIG has determined in an initial assessment that 91 percent of Medicare Part D compliance plans do not adequately address all CMS requirements for the eight compliance plan elements. In addition, CMS has outlined guidance to prevent fraud, waste and abuse in the Medicare Part D program. This mandate has caused companies to scramble, using scattershot auditing approaches to respond to the government's guidance. Unfortunately, this "boil the ocean" tactic is not the most effective approach. By addressing all potential risk areas in a uniform manner, companies risk overlooking the most pressing issues, addressing minor infractions rather than major abuses. To remedy this, a structured risk assessment framework is recommended so that your company can identify those areas that should be addressed immediately versus those that should be subsequently addressed. Polaris has a methodology that will allow you to do this.
