CMS has required that all providers who provide health care services to Medicare members under Medicare Advantage or Medicare Part D Programs complete compliance training on Fraud and Abuse by December 31, 2009. Many providers are unaware of this mandate, but the insurance carriers are taking it seriously. We have been advised by two insurance carriers that offer Medicare Advantage Programs that they will be enforcing the compliance training requirement.
If providers do not complete the compliance training the carriers can withhold payment for services or worse, terminate the provider’s contract. One of the carriers we have spoken with advised us that if the provider does not have a certificate on file stating they have completed the compliance training then they will withhold all payments. The other carrier stated that initially they will not withhold payment, but will contact any providers who do not have the certificate on file to discuss the training. However, if the providers who have not completed the training do not make attempts to comply they will eventually begin to withhold payments.
CMS offers an online training that takes about 85 minutes to complete. It can be found at http://cms.meridianksi.com . Some carriers who offer Medicare Advantage Plans are also offering their own compliance training plans that CMS is recognizing. Our local BC offers an online slide presentation that only takes about 10 minutes that qualifies. At the end of the training there is a certification statement that is to be completed. In this case, BC will keep the certification statement on file for the provider and will verify to any other insurance carriers of Medicare Advantage Plans that the provider has completed the training.
The compliance officer for the provider’s office must complete the training. Then they are responsible for educating their staff, either by having each staff member complete the training as well, or by having them complete a training that the compliance officer puts together as a result of the training they took. The training must be repeated on a yearly basis.