HISC is committed to the prevention, early detection and resolution of fraud, waste and abuse within its Medicare programs. The HISC Medicare Compliance Program shall consist of a comprehensive fraud, waste and abuse (FWA) program to detect, correct, and prevent fraud, waste, and abuse. This fraud and abuse plan includes procedures to voluntarily self-report potential fraud or misconduct related to the appropriate government authority.

The HISC FWA Program shall be reviewed annually and revised to reflect current FWA activities.

HISC believes that each employee and other individual who works with the Medicare program is key to Medicare program compliance, but the following areas play a specific role in with respect to fraud, waste and abuse:

• Special Investigations Department - conducts potential health care fraud, waste or abuse investigations. Maintains a 24/7 FWA Hotline. Refers cases to the MEDIC and law enforcement as appropriate.
• Audit Services - works with the Medicare Contract Office, and Corporate Compliance to conduct an annual risk assessment and develop the HISC Work Plan. Perform audits and reviews that target the identified risk areas. Coordinates all external audits.
• Medicare Contract Office (MCO) - responsible for oversight of the Medicare programs for HISC, including day-to-day operations, monitoring contracts to ensure deliverables are met, maintaining government relationships, overseeing subcontractor activities and participating in analysis of future opportunities in support of customer needs and corporate strategy.
• Corporate Compliance Department (CCD) - responsible for the management of the HISC Corporate Integrity and Compliance Program. The HISC Compliance Officer is responsible for developing, operating, and monitoring the FWA program.
• Prime Therapeutics - HISC's Pharmacy Benefit Manager's FWA Plan is integral to the HISC FWA Program and is incorporated into the HISC FWA Program. HISC utilizes Prime's FWA program components to prevent and detect potential FWA within the HISC Medicare Part D population including, but not limited to:
• Retrospective Drug Utilization Reviews
• Desk top and On-site audits
• Daily claims review
• Medication Therapy Management
• Quarterly review of high dollar claims

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