Helaine I. Fingold, a Senior Counsel in the Health Care and Life Sciences practice, in the firm’s Baltimore office, was quoted in Drug Benefit News, in “As CMS Rolls Out $9.6M in CMPs, 2015 Audits Show Part D Compliance Defects,” by Lauren Flynn Kelly.
Following is an excerpt:
“Whether it’s the ODAG or formulary and benefits that has been shown to be an issue, what has been discussed as a root cause in a lot of the cases is that those areas are being addressed by a vendor, not necessarily the entity itself,” points out Fingold, who has held various leadership roles at CMS. “It’s being managed downstream and CMS has been focusing on the need for sponsors to ensure appropriate oversight of vendors, to make sure sponsors are tracking what their vendors are doing to ensure that the vendors are in compliance with MA and Part D rules. There have been a lot of citations around formulary administration, for example. The plan’s formulary may have been filed with and approved by CMS, but someone at the PBM may have made an error in setting the formulary up in their system, resulting in unapproved edits, so that’s a particular issue that often gets cited.”
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