Fraud, waste and abuse
Understanding FWA compliance
All sites are required to comply with Medicare FWA and have FWA training on a yearly basis. Training can be accomplished by providing your own training (See CFR 422.504(b)(4)(vi)(c) or 423.504(b)(4)(vi)(c) “Effective training and education between the compliance officer and organization employees, contractors, agents, and directors.") Or complete training offered by Medicare Advantage or Part D Plan Sponsor or other CMS-approved training. You may find FWA training on the web. Some have a fee or Medicare provides training on their website at no cost.
What to do after training
After completing training, sites will need to complete and fax the attestation sheet to the Good Neighbor Pharmacy at 845.483.1556. (Note: If you use a different provider network such as Family Care Network, please contact them for their documentation requirements.) Sites are required to maintain training logs for all personnel that have completed FWA training. They should sign and date the log when they have completed the training. Sites should also have a Compliance Program Policy and Procedure Manual. IPN recommends that sites set up a 3-ring binder and label it Medicare FWA. In the binder, sites should keep training logs, a copy of the yearly attestation sheet, a copy of the training module reviewed for that year and a copy of the Compliance Program Policy & Procedure Manual that is required by Medicare. The documents contained in the IPN website for Medicare FWA should help set up a complete program to comply with the Medicare FWA requirements.
Please review these documents:
- Medicare Patient Rights
- Training Guidance
- Training Certification Requirements
- Frequently Asked Questions
- Attestation Form for Good Neighbor Pharmacy Provider Network
- Instructions for Attestation Form
- Policies and Procedures
- Training Log