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

If your practice or facility cares for Medicare-eligible patients, 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)?
A 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?
A Every individual who is associated with your practice or facility and works with Highmark’s Medicare Advantage and/or Medicare Part D Prescription Drug Plan (PDP) members 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:
  • At the beginning of their employment, contract, or appointment: Within 90 days
  • During employment, contract, or appointment: Between Jan. 1 and Dec. 31 every 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 the General Compliance Training and Fraud, Waste, and Abuse Training offered by your practice or facility
    • IMPORTANT DISCLAIMER: This training must include all 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 present one of the following acceptable forms of evidence:
  • 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?
A 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).