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DEPARTMENT OF HEALTH & HUMAN SERVICES Centers for Medicare & Medicaid Services 7500 Security Boulevard, Mail Stop C4-23-07 Baltimore, Maryland 21244-1850 CENTERS FOR MEDICARE &MEDICAID SERVICES CENTER FOR MEDICARE Date: June 17, 2015 To: All Medicare Advantage Organizations and Prescription Drug Plan Sponsors From: Gerard Mulcahy, Director Medicare Parts C and D Oversight and Enforcement Group Subject: Update - Reducing the Burden of the Compliance Program Training Requirements On May 23, 2014 the Centers for Medicare & Medicaid Services (CMS) published CMS -4159-F, Medicare Program; Contract Year 2015 Policy and Technical Changes to the Medicare Advantage and the Medicare Prescription Drug Benefit Programs. This memo provides guidance for how your organization can satisfy the requirements related to "Reducing the Burden of the Compliance Program Training Requirements" for sponsors and first-tier, downstream and related entities (FDRs) that was detailed in that final rule. See also (§§ 422.503(b)(4)(vi)(C)(3) and 423.504(b)(4)(vi)(C)(4)). Sponsors must provide general compliance and fraud, waste and abuse (FWA) training for all employees of their organization and entities they partner/contract with to provide benefits or services. Starting January 1, 2016, to comply with training requirements sponsors must accept from FDRs certificates of completion of CMS' training located on the Medicare Learning Network (MLN). CMS developed web -based compliance training to ensure the requirement is met and to reduce the largely duplicative training required of FDRs by the multiple organizations with whom they contract. The compliance and FWA training topics include: • Relevant laws and regulations related to Medicare Parts C and D FWA. • An overview of compliance expectations, how to ask compliance questions, request compliance clarification, hotline reporting. • Types of non-compliance and FWA that can occur in the settings in which sponsor and FDR employees work. • Processes for Sponsors and FDR employees to report suspected Medicare program non- compliance and FWA to the sponsor. ■ Case examples and resources. CMS recognizes that many organizations use sophisticated training mechanisms and invest substantial resources to deliver and track their employee's compliance with CMS requirements. In the final rule, CMS stated that we would consider and determine if the CMS training modules could be available in a format for downloading into organizations' existing training systems. To further minimize the administrative burden on Sponsors and FDRs, CMS is broadening the availability of the CMS compliance program training. Asuris Medicare Compliance CMS Memo 2015 A18816854AA Page 1 of 2