General Compliance And Fraud, Waste And Abuse (FWA) Training

General Compliance Education - Plan sponsors must ensure that general compliance information is communicated to their Vendor/FDRs including their PBM as a first tier entity. The plan sponsor’s compliance expectations can be communicated through distribution of the Navitus Code of Conduct and/or compliance policies and procedures to Vendor/FDRs’ employees. (Medicare Prescription Drug Benefit Manual Ch. 9 §50.3.1)

FWA Training - The PBM’s employees (including temporary workers and volunteers),governing body members, as well as Vendor/FDRs’ employees who have involvement in the administration or delivery of Part D benefits must, at a minimum, receive FWA training within 90 days of initial hire (or contracting in the case of Vendor/FDRs), and annually thereafter. PBMs must be able to demonstrate that their employees and Vendor/FDRs have fulfilled these training requirements as applicable. (Medicare Prescription Drug Benefit Manual Ch. 9 §50.3.2)

• Training
  • Take the CMS standardized FWA Training Module, available at https://www.cms.gov/outreach-and-education/medicare-learning-network-mln/mlnproducts/webbasedtraining
  • Use the CMS Standardized CMS general Compliance Training Module from 2019 at https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/Downloads/MedCandDGenCompdownload.pdf
  • Provide training with content that is substantially similar to and addresses core concepts and topics of CMS Standardized General Compliance and FWA Training modules to satisfy CMS requirements.
• If a pharmacy is completing a General Compliance and/or FWA training module mandated by another PBM, Plan Sponsor or health plan, that training may be used to satisfy this requirement if it satisfies the requirements above.
• Ensure that any of your employees, including temporary workers or volunteers, that support Navitus Medicare/Medicaid programs complete the training within 90 days of hire and annually thereafter.
• Maintain records of satisfactory general compliance and fraud, waste, and abuse training and education taken by your employees for 10 years.
  • The records must demonstrate the date of the training, the topic, attendance, and certificates of completion and/or test scores, if applicable.
  • Examples of proof of training may include copies of sign-in sheets, employee attestations and electronic certifications from the employees taking and completing the training.
• If you are “deemed” for FWA training, you do not need to take the CMS Standardized FWA training. Organizations are “deemed” if they have met the FWA certification requirements through enrollment into Parts A or B of the Medicare program or through.
• accreditation as a supplier of DMEPOS. However, Navitus must still communicate general compliance training to its employees. Navitus provides General Compliance information to you and your employees through  accreditation as a supplier of DMEPOS. However, Navitus must still communicate general compliance training to its employees. Navitus provides General Compliance information to you and your employees through:
  • This Vendor/FDR section of the Navitus website; and
  • The Navitus Vendor/FDR Education module.