Reporting Mechanism For Compliance And FWA Issues
Requirements | How to Comply |
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Plan sponsors must have a system in place to receive, record, respond to, and track compliance questions or reports of suspected or detected noncompliance or potential FWA from employees, members of the governing body, enrollees, and FDRs and their employees. Reporting systems must maintain confidentiality (to the greatest extent possible), allow anonymity if desired (e.g., through telephone hotlines or mail drops), and emphasize the plan sponsor’s / FDR’s policy of non-intimidation and non-retaliation for good faith reporting of compliance concerns and participation in the compliance program. FDRs that partner with multiple plan sponsors may train their employees on the FDR’s reporting processes including emphasis that reports must be made to the appropriate PBM to forward to the appropriate plan sponsor. The methods available for reporting compliance or FWA concerns and the non-retaliation policy must be publicized throughout the sponsor’s or FDR’s facilities. Plan sponsors must make the reporting mechanisms user friendly, easy to access and navigate, and available 24 hours a day for employees, members of the governing body, and FDRs. It is a best practice for plan sponsors to establish more than one type of reporting mechanism to account for the different ways in which people prefer to communicate or feel comfortable communicating.(Medicare Prescription Drug Benefit Manual Ch. 9 §50.4.2) |
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