Medicare FWA, SNP Model of Care and
Provider Marketing Training
In accordance with Centers for Medicare and Medicaid Services (CMS) regulations, Medicare Advantage organizations (MAOs) are required to establish, implement and ensure that all first-tier, downstream and related entities (FDRs) have taken and reviewed the following trainings and educational materials:
- Medicare Fraud, Waste, and Abuse Training
The Centers for Medicare and Medicaid Services (CMS) requires Medicare Advantage organizations (MAOs) to monitor and track its participating providers to ensure completion of the Fraud, Waste and Abuse (FWA) training requirements. For Cal MediConnect Plan (Medicare–Medi-Cal Plan) providers, these requirements are Medicare-specific, and not applicable to Medi-Cal.
FWA Training Requirements
Most of Health Net’s participating providers, or first-tier, downstream and related entities (FDRs), are deemed to have met the FWA training and education requirements due to their enrollment in Medicare Parts A or B, or have accreditation as a supplier of durable medical equipment, prosthetics, orthotics, and supplies (DME-POS). Therefore, this communication is directed to participating physician groups (PPGs), independent practice associations (IPAs) and medical groups and their employees.
Health Net PPG, IPA or medical groups delegated to perform administrative functions, such as claims processing, credentialing or utilization management, on behalf of Health Net are required to ensure their employees involved in these delegated functions receive FWA training within 90 days of initial hiring and annually thereafter by December 31, unless the PPG, IPA or medical group can demonstrate that they meet the requirements of the above deemed category.
CMS launched a standardized Medicare Parts C and D FWA training and education module through the CMS Medicare Learning Network (MLN) website under the Web-Based Training Courses link at:
Delegated PPGs, IPAs and medical groups should use this training module to satisfy the CMS training requirement for their administrative staff.
Training Attestation Record Maintenance Requirements
By March 31 of each year, delegated PPGs, IPAs and medical groups are required to attest that all identified staff completed the FWA training in the prior year. A parent PPG may submit one attestation on behalf of itself and its satellites. The attestation form may be faxed or emailed to Health Net’s Provider Network Management Department using the contact information provided on the form. There is an option on the attestation to indicate whether a PPG, IPA or medical group meets the requirements of the above deemed category. If this option is selected, supporting documentation must be faxed or emailed along with the attestation.
Delegated PPGs, IPAs and medical groups are accountable for maintaining FWA training records for a period of 10 years of attendance, topics, certificates of completion (if applicable), and test scores of any tests administered to their employees related to FWA training. This is subject to audit upon request from Health Net or CMS. Health Net continues to randomly conduct audits to ensure compliance with this requirement.
CMS FWA REGULATIONS AND REQUIREMENTS
These requirements are being implemented based on the following:
- Title 42 Code of Federal Regulations (CFR) 422.503(b)(4)(vi)(C), 423.504(b)(4)(vi)(C)
- CMS Medicare Managed Care Manual, Chapter 21 – Compliance Program Guidelines, and Prescription Drug Benefit Manual Chapter 9 – Compliance Program Guidelines, Section 50.3.2: Fraud, Waste, and Abuse Training
Additional Information (Health Net Providers and FDRs must ensure distribution of these documents to their employees and downstream entities within 90 days of hire, when updated, and annually thereafter):
- PPG/IPA/Medical Group FWA Training Attestation Form (pdf)
- Prompt Response to Detected Offenses (pdf)
- Effective Lines of Communication (pdf)
- Enforcement of Standards (pdf)
- Medicare Compliance Plan (pdf)
- Medicare-Medicaid Plan Compliance Plan (pdf)
- Monitoring and Auditing (pdf)
- Training and Education (pdf)
- Written Policies and Procedures and Standards of Conduct (pdf)
- Compliance Officer and Compliance Committee (pdf)
- Special Needs Plans Model of Care Initial & Annual Training
The Centers for Medicare and Medicaid Services (CMS) requires Medicare Advantage organizations (MAOs) to provide annual Special Needs Plans (SNP) Model of Care Annual training for all SNP participating providers (§422.102(f)(2)(ii)). In accordance with the regulations, Health Net has developed the SNP Model of Care Annual training. This requirement is applicable to SNP providers only.
CMS requires that SNP providers and appropriate staff (those involved in any aspect of the provision of SNP services) complete the SNP model of care annual training each year by December 31. The training can be provided in any of a variety of modalities, such as printed, face-to-face, Web-based, or audio and visual formats. SNP providers do not have to submit confirmation of training upon completion; however, providers are subject to audit by CMS and Health Net to demonstrate that the training was provided to appropriate staff. Therefore, providers must maintain training records, which may consist of a mailing list, fax list, sign-in sheet, or other formats. If you choose to use the model of care annual training that Health Net created, select SNP Model of Care Annual Training (pdf) to open the file and begin the training.
- Medicare Compliance Provider Marketing Training
The Centers for Medicare and Medicaid Services (CMS) Medicare Managed Care Manual provides specific guidance regarding marketing communications to Medicare-eligible members by health plans and their participating providers, hospitals, and ancillary providers. Health Net participating providers are required to comply with applicable Medicare laws and regulations, and Health Net policies and procedures when creating or distributing marketing materials.
Health Net has developed the online Medicare Compliance Provider Marketing Training (pdf) in an effort to provide a high-level overview of the CMS marketing requirements, including appropriate supporting documents, responsibilities and where to find forms and guidance.
For questions regarding Medicare marketing materials submission, or to submit Medicare marketing materials for approval, contact the Health Net Medicare Marketing Department by email at:
For updated and additional information regarding CMS Medicare marketing guidelines, refer to the CMS website at: