4. What topics must our general compliance and FWA training address?
Answer: Training must meet CMS requirements issued in Publication 100-16, Medicare Managed Care Manual, Chapter 21 and 100-18, Medicare Prescription Drug Benefit Manual, Chapter 9 (available at: http://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Internet-Only-Manuals-IOMs.html). At a minimum, training must include:
1. Standards of Conduct (also referred to as Code of Conduct or Code of Ethics) demonstrating the organization’s commitment to compliant, lawful and ethical conduct and written policies and procedures describing the operation of the compliance program;
2. The organization’s commitment to comply with applicable federal and state laws;
3. Well publicized disciplinary standards;
4. Guidance for reporting compliance concerns;
5. Description for prompt response to compliance issues/concerns;
6. The organization’s system for routine monitoring and identification of compliance risks; and
7. A statement that good faith reporting carries no retaliatory actions.
Note: As stated in #6, beginning 1/1/16, FDRs will be required to use CMS’ Compliance/FWA training module on the Medicare Learning Network (MLN) at: http://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/ProviderCompliance.html.