2026 PAAS Fraud, Waste & Abuse and HIPAA Compliance Program Updates

PAAS National® continuously monitors legislative and regulatory changes that may impact your Fraud, Waste & Abuse and HIPAA Compliance Program. We keep a close eye on enforcement from the Department of Justice, Office of Inspector General, State Attorney Generals, and Office for Civil Rights to help ensure the program meets interpretative standards. Furthermore, PAAS works to keep pace with Pharmacy Benefit Managers as they continue to add credentialing requirements that can be extremely difficult, and a significant nuisance, to independent pharmacies.

PAAS has implemented changes to ensure pharmacies continue to have a robust program in place. PAAS FWA/HIPAA compliance program members can login to the member portal to view the 2026 FWAC and HIPAA Updates. This year’s updates included:

  • An update to the partial dispensing policy
  • New sections for out-of-stock items, drug recalls and records related to Substance Use Disorder
  • Enhanced content for New York Medicaid (Section 12 and Appendix E, where applicable)
  • Notice of Privacy Practices (NOPP) revisions pursuant to 42 CFR Part 2 updates
  • Civil Money Penalties adjusted for inflation in the training and Program Guide 

Administrators should review all Compliance Tasks (located in the left-hand navigation on the PAAS Member Portal) at least annually to keep the program up-to-date and in compliance. Section 2.6 Updates of Policies and Procedures of your manual contains information on maintaining open lines of communication and the distribution of changes.

If you’re not a member of PAAS’ FWA/HIPAA compliance program, contact us today to add the program for a discounted rate!

Sara Hathaway, PharmD
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