Medicare Fraud, Waste and Abuse Training Requirements

Background
Independent Health is committed to ensuring its entire provider network meets all regulatory requirements set forth by the Centers for Medicare & Medicaid Services (CMS). Additionally, it is Independent Health’s goal to ensure that our members remain protected while receiving the highest level of care.

As such, through Independent Health’s contract with CMS, we are required to confirm that all entities we partner and contract with to provide benefits or services for Medicare members facilitate and complete 1) Medicare Parts C and D General Compliance Training and 2) Combatting Medicare Parts C and D Fraud, Waste, and Abuse (FWA) Training.

CMS requires that all providers and their appropriate staff participate in FWA training annually as mandated by 42 C.F.R §§ 422.503 (b)(4)(vi) and 423.504(b)(4)(vi): ( http://www.ecfr.gov/cgi-bin/text-idx?rgn=div8&node=42:3.0.1.1.9.11.5.4)

Who must complete the training?
Due to this requirement, Independent Health is requiring that each of its participating provider organizations complete an electronic attestation (at bottom of page) confirming that all workforce members of your organization/practice (e.g. medical doctors, mid-levels, ancillary providers, registered nurses, licensed practical nurses, administrative and office staff, technicians, coders, etc.) have been provided and completed this CMS training.

Any new employee who joins your team in the future will also be required to complete the training within 90 days of hire.

Providers deemed to 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 DMEPOS are NOT exempt from this Medicare Parts C and D General Compliance Training requirement. Therefore we ask that these organizations facilitate this additional training requirement and attest to Independent Health upon completion.

Although Independent Health will accept certificates of completion from the Medicare Learning Network (MLN), we are providing your organization the required training materials below in order to ease your organization’s administrative burden. The two separate training modules consist of the following topics (please note that the web links inside these PDF documents are not live links):

Please also note that this updated training was released by CMS in December 2015, so your office must complete the new training in order to attest to completing the training.

Completing the Independent Health FWA Attestation
The attestation should be completed at the organizational/Tax Identification Number (TIN) level. Therefore, each individual physician, practitioner, midlevel, employee, etc. does NOT need to complete the attestation individually. The attestation should only be completed once annually by an authorized representative on behalf of their entire organization and all individuals encompassed under their TIN.

Independent Health determined that fulfilling this attestation requirement at the TIN level (instead of at an individual level) will reduce administrative workloads to all organizations and ensure the training is disseminated to all impacted employees consistently.

Moving forward, Independent Health will open the FWA attestation period up on April 1 and it will close on September 30 each year. It is the responsibility of our providers to complete the training and attest to completing it before September 30 of each year.

For additional resources regarding compliance and FWA training, please visit the CMS website. If you have questions regarding this requirement, contact our Provider Relations Department via email at providerservice@servicing.independenthealth.com or by calling (716) 631-3282 or 1-800-736-5771, Monday through Friday from 8 a.m. to 6 p.m.