This policy establishes a procedure to maintain and implement an appropriate compliance plan that:

• Ensures compliance with all, state and federal regulations applicable to practice of pharmacy;

• Uses appropriate references for maintaining compliance (law manual, online access to regulations, etc.);

• Includes process for monitoring changes in laws and applicability to requirements;

• Includes process for development and revising this policy and procedure based on requirements and training of staff;

• Includes requirement for Fraud, Waste, and Abuse training;

• Includes processes for conducting internal audits and monitoring to ensure compliance.

This policy defines and describes examples of fraud, waste, and abuse and provides staff with steps for routine monitoring and auditing. It describes OIG and Medicaid exclusion lists and use of data analysis for fraud, waste, and abuse prevention and detection, procedures for prompt response to compliance issues, and implementation of a corrective action plan, investigation and reporting fraud, reporting to state and federal agencies in case fraud is discovered.

It describes penalties and consequences if fraud, waste, or abuse is discovered.

It addresses and explains the California False Claims Act.

It also includes a suspected fraud, waste, and abuse reporting form.