Medicare requires annual compliance and fraud, waste, and abuse (FWA) training for physicians and certain staff in practices contracted with any Medicare Advantage (MA) plan.
While physicians enrolled in traditional Medicare Part B and their staff are deemed to have met the training requirements for FWA, others enrolled in MA plans (Medicare Part C) must complete an online FWA course. All must take a compliance course.
But “practices as a whole should provide this type of training to all employees, regardless of health plan participation,” said Genevieve Davis, TMA’s associate vice president for health policy.
“Even though Medicare Part B doesn’t require that you take an actual fraud, waste, abuse course, if a practice is audited, the auditor may ask for proof of training in this area. Also, contracts with health plans other than Medicare Advantage plans most likely have requirements that practices provide compliance and FWA training to employees.” Even your professional liability insurance carrier may have similar staff training requirements, she said.
The easiest and cheapest way to get the training: Use these free online resources the Centers for Medicare & Medicaid Services (CMS) provides through its Learning Management and Product Ordering System:
- Medicare Parts C and D General Compliance Web-Based Training Course, Revised — covers how compliance programs operate and how to report compliance program violations.
- Combating Medicare Parts C and D Fraud, Waste, and Abuse Web-Based Training Course, revised — covers major laws and regulations; how to recognize FWA; potential consequences and penalties for violations; and preventing, reporting, and correcting FWA.
Special Requirements for MA Plans
If you are contracted with an MA plan, you must distribute a code of conduct and/or compliance policies (your own or the payer’s) to employees within 90 days of hire or contracting, when updates are made, and annually thereafter. You must train relevant staff within 90 days of initial hiring and annually thereafter. You and your staff can complete the annual training any time between Jan. 1 and Dec. 31 of any given contract year. Your payer may direct you to take its own free online training, which incorporates the CMS standardized training modules into the payer’s compliance training materials. In addition, MA plan contractors in Texas and some other states must complete Special Needs Plan Model of Care training available through the payer.
Once you’ve completed the training, you’ll need to submit an online acknowledgement according to the payer’s instructions. That’s because CMS requires insurance companies with MA plans to ensure their contracted physicians and office staff with access to Medicare patients’ information have received the required training.
Insurance companies periodically run reminders and instructions in their newsletters about completing this training.
Published Jan. 26, 2017
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