Blue Review

Medicare Advantage mandatory provider FWA training

Blue Cross and Blue Shield of Texas (BCBSTX) and Blue Medicare PPO are committed to complying with Centers for Medicare and Medicaid Services (CMS) requirements. To that end, we are committed to ensuring our contracted providers remain in compliance.

On Dec. 5, 2007, CMS published “Revisions to the Medicare Advantage and Part D Prescription Drug Contract Determinations, Appeals, and Intermediate Sanctions Processes; Final Rule,” which includes a requirement that Medicare Advantage plan sponsors provide all contracting providers (physician practices, facilities, DME providers, etc.) participating in a Medicare Advantage (Part C) network with fraud waste and abuse (FWA) training annually. The rule became effective Jan. 1, 2009.

CMS specifies that participation in this training is mandatory for anyone in the provider’s practice who may interact with a Medicare Part C beneficiary. BCBSTX leaves the decision as to who in the physician’s practice will complete the training to the discretion of the physician or compliance officer. The training must be completed by the end of the year in order for providers to remain active in the Blue Medicare PPO network for the following year.

This requirement grew out of an ongoing concern about the rising cost of health care, combined with the overwhelming number of FWA cases involving the Medicare program and its beneficiaries. BCBSTX/Blue Medicare PPO strongly supports this requirement because we believe it is the right thing to do.

To meet this requirement, BCBSTX/Blue Medicare PPO provides FWA training program for providers online. No special software is required; however, you will need an active Internet connection. To access the training, go to the Medicare Advantage Mandatory Provider FWA Training Web site at http://www.nmchili.org/2004/Conference04/ConfPlan.htm. You will find an attestation at the end of the course. The training will take approximately 45-60 minutes to complete. Please be sure to turn on the sound for your computer, as the training is narrated.

Providers who do not have Internet access can request the hardcopy training/attestation by calling 713-354-7685 for providers in the Houston area or 915-496-6600 (select option 2) for providers in the El Paso area. These providers will be required to fax their attestations to Blue Medicare PPO to receive credit for meeting the training requirement. The fax number is on the attestation form.

We recognize that because CMS requires that each Medicare Advantage plan sponsor make FWA training available to its participating providers, you could be inundated with training requirement requests depending on the number of Part C networks in which you are participating. In order to reduce the training burden, BCBSTX/Blue Medicare PPO does not require that you complete our FWA training course specifically. We will accept the following in lieu of our FWA course:

  • Completion of a FWA training course offered by any other Medicare Advantage plan sponsor with whom you are contracted.
  • Completion of a FWA training course on the Medicare Learning Network (MLN).
  • Completion of a FWA training course offered by a hospital where you have admitting privileges.
  • Completion of an in-house-developed FWA training course as long as it includes the following:
    • Information about the various laws and regulations related to FWA.
    • How to detect, prevent and correct FWA.
    • How and where to report potential FWA violations.
  • Completion of a vendor-developed FWA training course as long as it includes the following:
    • Information about the various laws and regulations related to FWA.
    • How to detect, prevent and correct FWA.
    • How and where to report potential FWA violations.

If you have already completed the FWA training provided by another Medicare Advantage plan sponsor, you can use that training to satisfy this requirement. Just go to the Medicare Advantage Mandatory Provider FWA Training Web site. Scroll down and click on the link that reads Providers who have already taken another Plan’s Part C and Part D training; this will take you directly to the attestation page. You must identify the source of the training on this attestation.

Upon completion of the training, BCBSTX/Blue Medicare PPO requires that the contracting physician or compliance officer complete our online certification attesting that all employees identified as requiring FWA training have completed it.

In addition, and in compliance with CMS regulations, the practice or entity will be required to maintain training logs and information regarding who completed the training, the date on which the training was completed, and information regarding the training program to be completed by each employee. These records must be maintained for a period of 10 years, which is the Medicare record retention period. These training records must also be made available to BCBSTX/Blue Medicare PPO as requested for audit purposes.

Thank you for your cooperation in complying with this important CMS requirement. If you have any questions, please contact your local professional provider network department. Contact information for your local contact is available at http://www.bcbstx.com/provider/contact_us.htm.

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Blue Review • Issue 1, 2010 • www.bcbstx.com