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Sponsors will have two (2) options for ensuring its FDRs (including the FDR's employees) have satisfied the general compliance and FWA training requirement that must be completed 90 days after initial hire/contracting and annually thereafter as described in the regulations and sub- regulatory guidelines. (1) FDRs and its employees can complete the general compliance and/or FWA training modules located on the CMS Medicare Learning Network (MLN). Once the individual completes the training, the system will generate a certificate of completion. The MLN certificate of completion must be accepted by all Sponsors. (2) FDRs may download, view or print the content of the CMS standardized training modules from the CMS website to incorporate into their organization's existing compliance training materials/systems. The CMS training content cannot be modified to ensure the integrity and completeness of the training. However, an organization can add to the CMS training to cover topics specific to their organization. Training materials are available at the following path: http:/Iwww.cros. gov/Outreach-and-Education/Medicare-Learning-Network- MLN/MLNProducts/ProviderCompliance.html CMS will accept either the MLN system generated certificates of completion, or, an attestation confirming that the organization has completed the appropriate compliance and FWA training. Attestations must include language specifying the entity complies with CMS compliance and FWA training requirements, and, if choosing to implement option (2) the training provided includes CMS content without modification. Further, sponsors and FDRs must maintain certificates or documentation of training completion and will furnish upon request a certificate of training such as certificates of completion, training logs, system generated reports, spreadsheets etc. FDRs providing training logs, reports, etc. must include at least employee names, dates of employment, dates of completion, passing scores (if captured) to clearly document training completion. Sponsors are required to validate that all of the general compliance and FWA training requirements are completed by their FDRs. In addition, Sponsors are accountable for maintaining records for a period of 10 years of the time and must require their FDRs to maintain training records of the FDRs' employees. While use of the web -based training via the CMS MLN website is optional for Sponsors employees, a benefit of using the web -based training and education modules is the ability to receive continuing education credits for course completion. Additional compliance information is available at: https:/Iw,,vN. cros. gov/Medicare/Compliance-and-Audits/Part-C-and-Part-D-Compliance-and- Audits/ComplianceProgramPolicyandGuidance.html More guidance regarding training and education requirements can be found in the Compliance Program Guidelines located in the Internet Only Manual (IOM) Pub. 100-16, Medicare Managed Care Manual Chapter 21, and IOM Pub.100-18, Medicare Prescription Drug Benefit Manual Chapter 9. Additional guidance on the specifications and new location of the web -based compliance training modules is forthcoming. For compliance -training related questions please contact: Parts—C_and—D_CP_Guidelines@cros.hhs.gov For FWA training—related questions, please contact: FWATraining@cros.hhs.gov Asuris Medicare Compliance CMS Memo 2015 A18816854AA Page 2 of 2