Key FAQs About Medicare Compliance and Fraud, Waste, and Abuse (FWA) Training

If your practice or facility cares for Medicare-eligible patients, please read this important notice and share it with your colleagues.

Q What kind of training is required by the Centers for Medicare & Medicaid Services (CMS)?

CMS requires Highmark’s Medicare First-tier, Downstream, and Related (FDR) Entities to complete two trainings:

  • Medicare Parts C&D General Compliance Training
  • Combatting Medicare Parts C&D Fraud, Waste, and Abuse (FWA) Training
Q Who must complete these trainings?

Individuals associated with your practice or facility who work with Highmark’s Medicare Advantage and/or Medicare Part D Prescription Drug Plan (PDP) members and who fall into one of these categories:

  • Employee
  • Governing-body member
  • Temporary worker
  • Contractor
  • Subcontractor
  • Volunteer
Q Why does CMS require these individuals to complete these trainings?
A CMS expects Highmark and its other Medicare-plan sponsors to ensure that all practices and facilities receiving Medicare dollars understand how to comply with the laws, regulations, guidelines, and policies for the Medicare program and how to prevent, detect, and correct Medicare fraud, waste, and abuse.
Q When does CMS require these individuals to complete these trainings?
A Both trainings must be completed:
  • Within 90 days of hire, contracting, or appointment
  • Annually thereafter (between Jan. 1 and Dec. 31 of any given contract year)
Q Where can individuals go to access these trainings?
A Individuals have three options for completing these training requirements. They can:
  • Complete both trainings online via the CMS Medicare Learning Network
  • Complete Highmark’s General Compliance Training and Fraud, Waste, and Abuse Training, which includes the CMS Medicare Learning Network Training. The course is located on the Highmark Provider Resource Center. To access the training, search using the keyword “Fraud.”
  • Complete the General Compliance Training and Fraud, Waste, and Abuse Training offered by your practice or facility as long as it includes all of the content included in CMS’s trainings, without any modifications.
Q What proof must be provided that the trainings were completed?
A Individuals must review the training programs in their entirety, and there must be some form of evidence that each individual completed the training. Acceptable forms of evidence include:
  • Sign-in sheets
  • Individual employee attestations
  • Electronic certifications
The records must include:
  • Time
  • Attendance
  • Topic
  • Certificates of completion (if applicable)
  • Test scores (if applicable)
Proof of training completion must be provided to Highmark upon request. Training records must be maintained for the period of the provider's contract with Highmark, plus an additional 10 years.
Q Are there any exceptions to these guidelines?

Yes. FDRs who have met the FWA training and education certification requirements through enrollment into Parts A or B of the Medicare program or through accreditation as a supplier of durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) are deemed to have met the training and educational requirements for fraud, waste, and abuse. However, these individuals are not exempt from the general compliance training requirement (the training is still required).

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Provider News, Issue 3, 2020   |   © 2020 Highmark Blue Cross Blue Shield Delaware