CVS Acquisition of Aetna Telemedicine and Durable Medical

Medicare Part D Compliance Newsletter for Vendors Quarter 3, 2019 Inside This Issue: CVS Acquisition of Aetna Page 1:

 CVS Acquisition of Aetna As your organization may already be aware, CVS Health acquired Aetna in 2018 and Aetna is now  Telemedicine and Durable part of the CVS Health family of companies. As a result of the acquisition, please be advised that Medical Equipment Fraud CVS Health and Aetna are consolidating FDR Oversight programs. Scheme Telemedicine and Durable Medical Equipment Page 2:

 Fraud Scheme Conflicts of Interest

In an overall effort to combat fraud, waste the equipment were obtained by the call Page 3: and abuse (FWA), First Tier, Downstream centers and then sold to DME companies  Compliance Word Search: and Related Entities (FDRs) should be who fraudulently billed Medicare and Conflicts of Interest aware of current FWA schemes impacting received kickback payments for these our Medicare members. Recently, the items. More information on this scheme Page 4: Important Resources Department of Justice (DOJ) and the can be found at the Department of Justice Medicare Fraud Strike Force announced law website.  Reporting Non- enforcement actions for one of the largest Compliance, and Fraud, Waste and Abuse health care fraud schemes involving We are looking into the impact of this  Key Links telemedicine and durable medical scheme for our members, but we also  Comments or equipment (DME) companies. This was want our FDRs to be aware since you may Suggestions? identified by Medicare beneficiaries interact with or receive questions from contacting the Medicare fraud hotline and our Medicare members. Please remember raising concerns about telemarketing that if you suspect or identify potential practices. fraud, waste or abuse that affects our Medicare members, you are obligated to According to the DOJ, an international inform us right away. telemarketing network used their call centers to contact Medicare beneficiaries If you have a compliance, fraud, waste or and offer them “free or low-cost” medical abuse concern you would like to report, equipment. The type of equipment included please feel free to reach out to our Ethics back, shoulder, wrist and knee braces Line at 1-877-CVS-2040. The Ethics Line is regardless of whether the items were available 24 hours per day, seven days per medically necessary. Medicare coverage week, 365 days per year. All calls will be was verified over the phone and then the treated confidentially. You do not have to beneficiaries were transferred to identify yourself. CVS Health prohibits telemedicine companies for consultations retaliation against anyone for raising a with physicians. legal or ethical concern in good faith or for cooperating with an investigation. These physicians had never met, seen or interacted with the beneficiaries. They were being paid by the telemedicine companies to prescribe medical equipment. Orders for

Medicare Part D Compliance Newsletter for Vendors Quarter 3, 2019

Conflicts of Interest A conflict of interest (COI) may arise when an How your organization distributes COI individual allows the prospect of personal gain information to these individuals may vary, to improperly influence the manner in which but some examples of acceptable he or she conducts business. Situations distribution include: involving a COI may not always be obvious or  Electronic training that contains easy to resolve. Some circumstances that may COI information present an actual or potential COI include, but  Distribution of a COI policy are not limited to:  Inclusion of COI in the Code of  Outside employment Conduct  Participation in outside organizations including board positions An industry best practice is to collect a  A financial interest in a competitor signed attestation from these individuals in  Employment of relatives which they each attest to being free from COI in administering or delivering Medicare A written policy and procedure that describes benefits. Just be sure your organization can COI, how to report a potential or actual COI, document that you ensured these individuals were free from COI at the time and the actions your organization takes when a potential or actual COI is identified is essential of hire or beginning work on the CVS account, as well as annually. for FDRs. Don’t forget to distribute this policy and procedure to anyone that works on or oversees the CVS account. This includes employees, temporary employees, volunteers, consultants, governing body members, officers, directors, and managing employees.

Medicare Part D Compliance Newsletter for Vendors

Quarter 3, 2019 Compliance Word Search: Conflicts of Interest

Medicare Part D Compliance Newsletter for Vendors

Quarter 3, 2019

Important Resources

Reporting Fraud, Waste or Abuse, or Non-Compliance

Don’t forget to report to CVS Health any and all known compliance concerns and potential FWA, that impact the contracted services performed on behalf of CVS Health. Reports of potential non-compliance or FWA can be made to the CVS Caremark Part D Services’ Fraud, Waste and Abuse Program by email at [email protected], by calling the Fraud, Waste and Abuse Hotline at 1-888-277-4149 or anonymously by calling the CVS Health Ethics line at 1-877-CVS-2040.

Key Links

Medicare Prescription Drug Manual

Medicare Prescription Drug Manual Chapter 9

Exclusion Lists  OIG LEIE LIST  GSA EPLS LIST

Comments or Suggestions?

In an effort to enhance the value of this communication, we welcome your comments or suggestions regarding the content of this newsletter. You can direct your remarks to [email protected].

In an effort to enhance the value of this communication, we welcome your comments