Medicare Advantage Plans requiring Compliance and Fraud, Waste, and Abuse training

If you participate in a Medicare Advantage (MA) plan, you may have recently received information that modifies your contract to ensure that the MA plans – and the providers within their networks – are compliant with all Centers for Medicare & Medicaid Services (CMS) mandates.  Two of these mandates may seem new to you; they are: 1), Compliance training, and 2), Fraud, Waste, and Abuse (FWA) training.

CMS has long required that all providers for MA plans provide proof of completion for Fraud, Waste, and Abuse (FWA) training.  You are required to repeat the training and provide proof of completion on an annual basis. The purpose of the training is to assist practices with identification of FWA and develop internal policies and procedures to find and fight abuse.

Compliance training may seem new to many practices and providers although it was mandated by the Affordable Care Act (ACA).  You can link to a CMS Compliance webinar presentation here on the subject.  The webinar quotes Section 6401 of the ACA, which provides that a “provider of medical or other items or services or supplier within a particular industry sector or category” shall establish a compliance program as a condition of enrollment in Medicare, Medicaid, or the Children’s Health Insurance Program (CHIP).   The ACA also requires the Secretary of Health and Human Services (HHS), in consultation with the HHS Office of Inspector General (OIG), to establish the “core elements” and a timeline for implementation.  Importantly, neither has been forthcoming from HHS and an enforcement date has not been published.

Some plans offer an on-line training program that provides an attestation that you have completed this task.  Many plans direct providers and staff to the already-approved CMS-based training on these topics.  Other compliance and FWA training programs may be adequate as well; check with the plans to ensure that is so.  Providers may be asked to prove to the plan that the training has been completed for themselves and their staff.  This might be done via a dated certificate of completion or some other method of attestation; be sure to save these proof documents so that they can be retrieved later if needed.

Because of this mandate, some practices may wish to have a formal Compliance Plan document; Corcoran Consulting Group has such a document template that we will help you customize it based on your specific needs.

As always, if you need other assistance – such as training for coding or documentation, or desire a review of your documentation or current fees, Corcoran Consulting Group can help.  Visit our website or call us to learn more.   (800) 399-6565

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