Common Questions
Fraud, Waste and Abuse
Do the policies and procedures that a sponsor must have in place to detect and reduce fraud, waste, and abuse, have to be in place at the time the sponsor submits its application?
ANSWER: Yes.
Answer ID: 400-1
Date Posted: 08/09/2010
The regulations require that the sponsor attest that it has fraud, waste and abuse policies and procedures in place, in order for an application to be approved. Is this requirement satisfied if an entity that is contracted with a sponsor that pays the sponsor's claims, and/or submits ERRP reimbursement request to HHS, has fraud, waste and abuse procedures in place?
ANSWER: Provided the contracted entity's fraud, waste, and abuse policies and procedures have the ability to effectively detect and reduce fraud, waste and abuse related to the Early Retiree Reinsurance Program, and the sponsor can ensure that the policies and procedures are produced upon the request of the Secretary of the U.S. Department of Health & Human Services, the contracted entity's fraud, waste, and abuse policies and procedures would satisfy this requirement. We would expect that any entity contracting with a sponsor that is vulnerable to fraud, waste and abuse would have policies and procedures in place.
Answer ID: 400-2
Date Posted: 08/09/2010
Do the policies and procedures that a sponsor must have in place to detect and reduce fraud, waste, and abuse have to specifically reference, or be specifically designed for, the ERRP?
ANSWER: No. However, the policies and procedures must have the ability to effectively detect and reduce fraud, waste, and abuse related to the Early Retiree Reinsurance Program. Sponsors will be required to attest, in their program applications, that they have such policies and procedures.
Answer ID: 400-3
Date Posted: 08/09/2010