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OOPARTMl!NT OP HEAL TH It. HUMAN SERVICES Centers for Medicare & Medicaid 5en,1c;es 7500 S@curity BoulQva,d, Mall Stop C4-23-D7 Balt imore, Maryland l12~4-l8S0 Date : To: From: Subject: June 17, 2015 All Medicare Advantage Organizations and Prescription Drug Plan Sponsors Gerard Mulcahy, Director Medicare Parts C and O Oversight and Enforcement Group Update • Red ucing the Burden of the Compliance Program Training Requ irement& 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 th11 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 entitles (FORs) 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 pro11ide tM!nefits or services. Starting January 1, 2016 , to comply with training requirements sponsors must accept from FDRs certificates of completion or CMS' training localed on the Medicare Leaming Network (MLN). CMS developed web-based compllance trainlng to 11na11re 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 compHance clarification, hotllne reporting. • Types of non-compliance and FWA that can occur In the settings in which sponsor and FDR employees work . • ProceHes for Sponsors and FOR 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 d11liver 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 module& could be available In a fonnat 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 . A1uria Medicare Compliance CMS Memo 2015 A 18816854AA P111e 1 of 2