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Sponsors Will have two (2) options for enSYrtng Ila FORa ~ncluding the FOR'e employees) hava setlsfled <br />the general compliance and FWA training requ lrt1ment that must be completed ea days after lnlllel <br />hire/contracting and annually thereafter as described In the regulations and sub-regulatory guidelines. <br />( t) FDRs 1ind Its employees can complete the general compliance and/or FWA training modules <br />located on the CMS Medicare Leaming Network (MLN). Once the Individual completes the <br />training, the system wlll generate a certificate of completlon. The MLN certl!lcate of completion <br />must be accepted by all Sponsors. <br />(2) FDRs may download, view or print the content of the CMS standardlZed training modules from <br />the CMS website to incorporate into their organization's existing compliance training <br />materials/systems. The CMS training content cannot be modified to ensure the integrity and <br />completenesa of the training. However, an organization can add to the CMS training to cover <br />topics specific lo their organlZallon. Training materials are available at the following path: <br />http ://www .cms .gov/Outreach-and-Education/Medicare-Learning-Network- <br />M LN/MLNProduclsl ProviderComp liance html <br />CMS will accept either the MLN aystem generated certificates of completion, or, an atte9tation confirming <br />that the organization has completed the appropriate compliance and FWA training. Attestations must <br />include language specifying the entity compiles wlth CMS compliance and FWA training requirements, <br />and, if choosing to implement option (2) the training provided includes CMS content without modification. <br />Further, sponsors and FDRs must maintain certlffcates· or documentation of training completion and will <br />furnish upon request a certificate of training such as certificates of completion, training logs, system <br />generated reports, spreadsheets etc . FDR11 providing training logs, reports, etc. must include at least <br />employee names, date11 of employment, datea or completion, passing acores (If captured) to clearly <br />document training completion. <br />Sponsors are required to validate that aN of the general compliance and FWA tralning requirements are <br />oompleled by their FDRs. In addltlon, Sponsors are accountable for maintaining records for a period or 10 <br />years of the lime and must require lheJr FDRs to maintain training records of the FCRa' employees. <br />While use of lhe web-baaed training via the CMS MLN website Is opllonal for Sponsors employees , a <br />benefit of using lhe web-based training and education modules Is the ablttty to receive cohtlm,dng <br />education cred lta for oourse compleUon. <br />Addltional compUance Information Is avallable at: <br />htlps:t/www.cms.gov/Medlcare/Compliance•and•AudJts/Part-C-and-Part-D-Complience-and• <br />Audits/ComplianceProgramPolicyandGuidance.html <br />More guidance regarding tra ining and education requirements can be found In the Compliance Program <br />Guldef fnea located In lhe tntemet Only Manual (IOM) Pub. 100-16, Medicare Managed Care Manual <br />Chapter 21 , and ICM Pub.100-18, Medicare Prescription Drug Benefit Manual Chapter 9. Additional <br />guidance on the specfflcaticna and new location of the web-based compliance training modul111 la <br />forthcoming. <br />For compllanc•tralning related questions please contact : Parts_c_and_D_CP _Guldellnes@cms.hhs.gov <br />For FWA training-related questions, please contact : FW ATraining@cms.hhs.gov <br />Aaurla IIA•dlcale Compliance CMS Memo 2015 Page2 Of 2