CMS Requirements for a Medicare Part D Fraud, Waste and Abuse (FWA) Compliance Training and Education Program ("The Program"):
- FWA Training is done for all employees at hire and annually thereafter.
- FWA Training emphasizes a commitment to comply with applicable statutory, regulatory, and other requirements, including but not limited to:
- Federal and State False Claims Acts
- Anti-Kickback Statute
- Health Insurance Portability and Accountability Act
- Guidance provided by CMS for Part D
- The Program provides for regular review of disciplinary guidelines for non-compliant or fraudulent behavior which results in mandatory retraining and may result in disciplinary action, including possible termination when such behavior is serious or repeated or when knowledge of a possible violation is not reported.
- The Program requires attendance and participation in formal training programs as a condition of continued employment, and a criterion to be used in employee evaluations. Geisinger Health Plan encourages the adoption of a Code of Conduct that reflects a commitment to detecting, preventing and correcting fraud, waste and abuse in the administration or delivery of Part D benefits.
- The Program provides for regular review of policies related to contracting with the government, such as the laws addressing fraud and abuse or gifts and gratuities for Government employees.
- The Program provides an emphasis on confidentiality, anonymity, and non-retaliation for compliance related questions or reports of potential non-compliance.
- The Program includes a process to comply with the ten-year record retention requirement as listed in the Federal Regulation and all clarifying instructions subsequently issued by CMS.
- The Program requires certification that the Office of Inspector General and General Services Administration exclusion lists are reviewed upon initial hiring and annually thereafter to ensure that anyone responsible for administering or delivering Part D benefits is not excluded from Federal health care programs. The Program further requires that if any employee is on such lists, that employee will immediately be removed from any work related directly or indirectly to all Federal health care programs and the employer will take appropriate corrective actions.
- Proof of training must be maintained and be readily retrievable and provided upon request by the Health Plan.
- Click here to review the FWA compliance training
- Click here to review the Geisinger Health Plan Code Of Conduct
