It's that time of year again. Not just the holidays, but the time of year plan sponsors ask for attestation from providers indicating General Compliance and Fraud, Waste, and Abuse training has been completed by those required to do so.
The Centers for Medicare & Medicaid Services (CMS) requires oversight of first tier, downstream, and related entities (FDRs) under the Medicare Advantage program. This includes making sure FDRs, including providers, have implemented the following:
- Written policies and procedures and standards (code) of Conduct.
- General Compliance and Fraud, Waste, and Abuse (FWA) Training. If you participate in Medicare Parts A or B, you are deemed to have met this requirement.
- Exclusion List Screening (e.g., OIG's Exclusion List).
- The availability of a system to receive reports (reporting mechanism) of suspected noncompliance and/or FWA that is confidential, allows anonymity, and includes a policy of non-intimidation and non-retaliation.
- Monitoring and auditing downstream entities.
- Identification of use of offshore subcontractors.
This is why you may receive a request from a plan sponsor asking for you to complete an attestation, Medicare plan sponsors are required to communicate their general compliance expectations to their FDRs through distribution of the plan sponsor's Standards of Conduct and/or compliance policies and procedures to FDRs' employees.
If you have additional questions about attestation or Corporate Compliance requirements, please do not hesitate to contact us by email: support@hcp.md or by phone 855-427-0427.