Franklin Technology Services LLC DBA LowerMyRx (“LowerMyRx” or “we” or “us”) is committed to legal and ethical business practices and it takes compliance with healthcare laws very seriously. But it doesn’t stop with us. Compliance is everyone’s responsibility! To this end, we require all personnel, vendors, contractors, and partners to review the following summary of key compliance issues related to our business offerings:
LowerMyRx expects you to conduct yourself in an ethical and legal manner. It’s about doing the right thing!
Act fairly and honestly
Adhere to high ethical standards in all that you do
Comply with all applicable laws and regulations, and
Report suspected violations:
2) Toll-Free Telephone:(877) 202-1910
Failure to follow all applicable healthcare laws and regulations can lead to serious consequences, including:
Exclusion from participating in all Federal healthcare programs
Civil monetary penalties
Prescription Drug Discount Cards and Programs
Prescription discount card services are highly regulated by state and federal governments, and our compliance with these laws is not only monitored by government regulators, but also by our customers, competitors, and the public at large. In other words, someone is always watching.
LowerMyRx expects its employees, vendors, contractors, and partners to comply with all laws and regulations governing prescription drug discount cards. This includes providing clear and consistent information to discount card members, with particular regard to the following points:
Healthcare Fraud, Waste, and Abuse
The federal government and many state governments have adopted laws that prohibit conduct that can cause fraud, waste, and abuse in healthcare programs. Whether certain laws apply to a business arrangement or a product depends on the facts, by Franklin Technology Services LLC DBA LowerMyRx requires and expects its vendors, contractors, and partners to comply with these laws, consider the implications of them in all business dealings, and engage in ethical busines practices.
(a) Is an intentional act of deception, misrepresentation, or concealment in order to gain something of value
(b) Often involves billing for services that were never rendered or billing for services at a higher rate than is actually justified.
(a) Is over-utilization of services and misuse of resources
(b) Is generally not considered to be caused by criminally negligent actions but rather by the misuse of resources
(a) Is the excessive or improper use of healthcare services or actions that are inconsistent with acceptable business and/or medical practice
(b) Refers to incidents that, although not considered fraudulent, may directly or indirectly cause financial loss.
Laws Targeting Healthcare Fraud, Waste, and AbuseTo ensure appropriate business relationships, LowerMyRx requires its vendors, contractors, and partners to specifically refrain from the type of conduct prohibited by the following federal laws:
(a) The Anti-Kickback Statute makes it’s a criminal offense to knowingly offer or receive anything of value (e.g., money) to induce referrals of items or services payable by a federal healthcare program, such as Medicare or Medicaid. In some industries, it is acceptable to reward those who refer business to you. However, in the Federal healthcare programs, paying for referrals is a crime.
(b) A violation of the Anti-Kickback Statute can occur if any one purpose of the arrangement is improper, even if other purposes exist that do not implicate the Anti-Kickback Statute.
(c) Violations of the Anti-Kickback Statute may be criminal or civil and are punishable by imprisonment, substantial fines, or both. Most states have adopted laws that mirror the Anti-Kickback Statute and apply outside of federal healthcare programs.
Civil Monetary Penalties (CMP) Law
(a) Among other things, the CMP Law imposes civil fines on any person who offers or provides anything of value (e.g., money) to a Medicare or Medicaid beneficiary that is likely to influence the beneficiary’s selection of a particular provider or supplier for any item or service reimbursable by Medicare or Medicaid. Many states have adopted laws that mirror the CMP Law and apply outside of federal healthcare programs.
Healthcare Fraud Statute
(a) The Healthcare Fraud Statute makes it a criminal offense to knowingly and willfully execute a scheme to defraud a healthcare benefit program. Healthcare fraud is punishable by imprisonment up to 10 years. It is also subject to criminal fines of up to $250,000.
(b) Conviction under the statute does not require proof the violator had knowledge of the law or specific intent to violate the law.
How do you prevent fraud, waste and abuse?
(a) If you would prefer to make a confidential, anonymous report, you can use one of these reporting options:
So . . . what CAN'T I do?
DON’T offer money, gifts, kickbacks, bribes or anything else of monetary value to doctors, nurses, pharmacists, pharmacy techs or interns, or other healthcare providers or pharmacy employees to promote LowerMyRx, the Program or any white-labeled service of LowerMyRx (or otherwise) or to enroll members in the Program or the LowerMyRx Program.
DON’T use ANY marketing materials that have not be pre-approved by LowerMyRx. That means web sites, physical cards, emails, faxes, flyers, text messages, apps or any other kind of marketing or solicitation materials you can think of.
DON’T use the trademarks, names, or logos of other businesses in your marketing materials unless you have the right (a license) to do so and unless your marketing materials have been approved by LowerMyRx.
DON’T imply or state that the Program is insurance coverage or a replacement for insurance. DON’T charge a fee for participation in the Program. The Program is free to consumers.DON’T make any statements about the LowerMyRx Program that we have not expressly approved.
DON’T ignore compliance or think “Someone else is handling that.” Compliance is everyone’s responsibility, including yours.
So . . . what CAN I do?
DO engage in open and honest marketing efforts. Explain the value of doing business with the Program to offer prescription discounts.
DO communicate clearly regarding prescription drug discount cards and how the LowerMyRx program works.
DO report to LowerMyRx any instance in which you become aware of a pharmacist demanding or receiving money or anything of monetary value for agreeing to promote LowerMyRx, the Program or any competing managed pharmacy program.
DO take compliance seriously. Conduct yourself in an ethical and legal manner. Act fairly and honestly in all business dealings.
DO act in a manner that does not conflict with, contradict, or otherwise misrepresent LowerMyRx’s mission and vision.
DO ask questions! If you have questions or concerns, reach out to email@example.com.
Data Use, Information Security & Privacy
LowerMyRx expects its vendors, contractors, and partners to protect all data and information related to LowerMyRx’s business; and to comply with all applicable laws pertaining to the confidentiality, privacy, data security, and data use as set forth in our agreements.
LowerMyRx may conduct oversight of the services you perform to ensure that you are complying with the requirements explained in this Compliance Standards and applicable laws, rules, and regulations. LowerMyRx may periodically ask you to complete a self-assessment, survey, and/or attest to applicable policy, procedure and compliance requirements. LowerMyRx may also perform on-site audits or inspections of facilities, procedures, and records that relate to the services provided under your contractual agreement.
Reporting Compliance ConcernsReporting compliance concerns is everyone’s responsibility. You play a vital part in preventing, detecting, and reporting potential noncompliance. Please report any suspected cases of noncompliance without fear of retaliation or retribution for reports made in good faith:
(b) Toll-Free Telephone:(877) 202-1910
By signing below, I certify that I read and understood the information provided in these Compliance Standards (the “Standards”) and certify that I commit to complying with all the laws and requirements they set forth.
I understand that any violation of these Standards is a violation of the terms and conditions of my Agreement with Franklin Technology Services LLC DBA LowerMyRx, and could result in the enforcement of legal remedies against me, including, but not limited to, termination of my Agreement with LowerMyRx and the forfeiture of any amounts due thereunder. I further understand that a violation of these Standards may also subject me to federal and state civil and/or criminal culpability.
I also understand that no statement contained in these Standards creates any guarantee of continued contract or employment, or creates any obligations, contractual or otherwise, on the part of LowerMyRx. These Standards are not promissory and do not set terms or conditions of employment or create an employment contract.
Franklin Technology Services LLC DBA LowerMyRx (“LowerMyRx”) and the undersigned Affiliate have a mutual desire to maintain effective compliance and ethics programs in support of the pharmacies who administer the prescription discount program provided by LowerMyRx (the “LowerMyRx Program”) and the patients who use these programs. As evidence of this commitment, LowerMyRx seeks to confirm the Affiliate’s efforts as a compliment to the contractual obligations between the parties (which remain in full force and effect and unmodified hereby).
For purposes of this attestation, Affiliate represents and warrants the following:
The Affiliate attests that it is upholding these compliance and ethics standards and that the Affiliate has disclosed applicable impacts to LowerMyRx.
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Document Name: Compliance Statement
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