Yes, I could just add that with the provisions we've now put in place--and I'm pleased the Auditor General has recognized that we now meet our obligations under sections 33 and 34—they are a much more rigorous process. What we have with the contractor is they submit to us a bill for their services, which is the payment processing, plus the bills they refund to the providers. So a person goes to a pharmacy, the pharmacy sends their bill to First Canadian Health, and First Canadian Health processes that and refunds the money to the pharmacist, and then they gather up these accounts and send them to us. There are over 15 million charges in a year, so we get a payment every two weeks.
At the moment we have a review of the bill that's received by Health Canada from First Canadian Health. We actually have a sampling frame that goes in and picks bills to make sure the bill they're submitting to us is justifiable. We then relate the payment they're asking for to the processing of the number of client services that have been rendered, and then we justify that to the penny, to make sure the bill they're giving us reconciles with the actual services they've performed.
In addition to that, we have a number of provisions that try to improve the accountability of the service. We have a next-day claims verification review, where we actually review the claims that come in every day against a certain template that says what's likely to be the provider's experience. If there are outliers, if one drugstore is providing many, many prescriptions out of the ordinary, we would put a flag on that and there would be an inquiry.
The contractor on our behalf sends quarterly letters to randomly selected clients, so we are able to see whether the clients actually had the service we're being billed for from First Canadian Health. We conduct a monthly post-payment account verification, where we take a random sample of claims and verify that the benefit is required. So we actually go to the First Canadian Health offices and look in their books to see that there actually was a payment made to that random sample and that the payment we had was then double-checked against the payment they made to the supplier.
We also conduct a biannual risk and trend analysis that profiles providers. So if we see behaviour that is out of the ordinary, we flag that, and we then have on-site verification for the providers where we pick a sample based on those risk assessments of who we should look at, and we send people to the pharmacies or dentists' offices to verify the accounts.