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ANNUAL COMPLIANCE AND FRAUD WASTE AND ABUSE (FWA) ATTESTATION


OR
Certification Summary

As required by the Centers for Medicare & Medicaid Services (CMS), Medicare Advantage Organizations (MAOs) and Prescription Drug Plans (PDPs) must establish, implement and provide effective training and education programs for its first tier, downstream, and related entities (FDRs) within 90 days of contracting and annually thereafter.

This annual Compliance and FWA Attestation is for Pharmacies (Organizations) participating in the AultCare Pharmacy Network, which includes PrimeTime Medicare (Part D) Network.

To ensure consistency and reduce burden on providers, suppliers, contractors and Sponsors, CMS has created the web-based training module to satisfy the general compliance, as well as the FWA training and education requirements (Medicare Parts C and D Fraud, Waste, and Abuse and Medicare Parts C and D General Compliance Training). The updated training satisfies the regulatory requirement for effective training and education (42 C.F.R. §§ 422.503(b)(4)(vi)(C) and 423.504(b)(4)(vi)(C).

In order to satisfy this requirement, CMS provides Sponsors with two (2) options for ensuring its FDRs (including the FDR’s employees) have satisfied the general compliance and FWA training requirement that must be completed 90 days after initial hire/contracting and annually thereafter as described in the regulations and sub-regulatory guidelines.

Option 1: FDRs and its employees can complete the general compliance and/or FWA training modules located on the CMS Medicare Learning Network (MLN). Once the individual completes the training, the system will generate a certificate of completion. The training module is available at the following path:
http://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/WebBasedTraining.html

Option 2: FDRs may download, view or print the content of the CMS standardized training modules from the CMS website to incorporate into their organization’s existing compliance training materials/systems. The CMS training content cannot be modified to ensure the integrity and completeness of the training. However, an organization can add to the CMS training to cover topics specific to their organization. CMS training materials are available at the following path:
http://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/ProviderCompliance.html
(*Note – the training is also posted on our website at www.primetimehealthplan.com under the Provider tab.)

In order to communicate our compliance expectations for FDRs, our PrimeTime Health Plan’s Code of Business Conduct and Ethics, Compliance Program and Compliance / FWA Contact information are all available to you and your affiliates on our website at www.primetimehealthplan.com under the Provider tab.

For our records, please complete the below attestation at your earliest convenience, or by December 31, 2017. Upon completion of this attestation, your Organization will have attested and certified that the Medicare Part D Compliance and FWA Training required of first tier, downstream, and related entities was completed in compliance with the below requirements.

Please contact our Compliance Department with any questions or concerns at PTHPCompliance@aultcare.com.

2017 Annual Attestation Statement
By submitting this attestation as an authorized representative of your Organization (Delegate), you certify as follows:
  • I attest that all employees and/or delegates, Contractors*, Agents, Board Members, and Consultants who provide administrative services or health care services to a Medicare eligible individual under the Medicare Advantage Part C or Part D program received Medicare Advantage and Part D Compliance training as well as specialized compliance training, as applicable within the first ninety (90) days of employment/contracting. Also all employees, Contractors, Agents, Board Members, and Consultants received the Medicare Advantage and Part D annual Compliance training as well as specialized compliance training, as applicable. (42 C.F.R. §§ 422.503(b)(4)(vi)(C), 423.504(b)(4)(vi)(C)) *FDRs are deemed to have met FWA training if they are a deemed Medicare Provider, an accredited DMEPOS organization or a Medicare-enrolled pharmacy.
    • Medicare Learning Network - CMS Medicare Parts C & D Fraud, Waste and Abuse Training and General Compliance Training
    • Completed Incorporated CMS Medicare Parts C & D Fraud, Waste and Abuse Training and General Compliance Training, without modification, into organization’s existing compliance training.
      • If utilizing this method, please have a copy of your training available upon request
  • I attest that all employees and/or delegates, Contracts, Agents, Board Members, and Consultants, who provide administrative services or health care services to a Medicare eligible individual under the Medicare Advantage Part C or Part D program received appropriate education and training on how to report suspected or detected noncompliance or FWA (i.e. hotlines, compliance personnel) and the training emphasized confidentiality, anonymity, and non-retaliation for compliance related questions or reports of suspected or detected noncompliance or potential FWA.

    Additionally, your organization has well-publicized disciplinary standards which encourage good faith participation in the compliance program and these standards include policies that articulate expectations for reporting compliance issues and assisting in their resolution; identifying noncompliance or unethical behavior; and providing for timely, consistent, and effective enforcement of the standards when noncompliance or unethical behavior is determined. (42 C.F.R. §§ 422.503, 423.504)
  • I attest that all employees and/or delegates, Contractors, Agents, Board Members, and Consultants received a copy of the PTHP Code of Ethics/Standards of Conduct which includes the organization’s Conflict of Interest policy. Alternately, your organization has comparable policies and procedures and Standards of Conduct and they are available upon request. (42 C.F.R. §§ 422.503(b)(4)(vi)(A), 423.504(b)(4)(vi)(A)
  • I attest that all employees and/or delegates, Contractors, Agents, Board Members, and Consultants were verified at the time of hire/contracting and monthly thereafter that the individual or entity is not excluded to participate in Federally funded health care programs according to the DHHS OIG List of Excluded Individuals and Entities (LEIE list) and the GSA Excluded Parties Lists Systems (EPLS) The Act §1862(e)(1)(B), 42 C.F.R. §§ 422.503(b)(4)(vi)(F), 422.752(a)(8), 423.504(b)(4)(vi)(F), 423.752(a)(6), 1001.1901
  • I attest that our organization maintains certificates or documentation of training completion for each employee and will furnish upon request a certificate of training such as certificates of completion, training logs, system generated reports, spreadsheets etc. for a period of 10 years.
  • Please retain a copy of the completed attestation for documentation. We may ask you to present a copy of the signed attestation for audit purposes.
  • ***PrimeTime Health Plan’s Compliance Program, Code of Ethics/Standards of Conduct, and Compliance Policies and Procedures are available at www.primetimehealthplan.com/Providers
  • *** Everyone has the right and responsibility to report possible non-compliance and fraud, waste, or abuse without fear of retaliation. All associated employees may contact the PTHP Compliance and/or FWA hotline anonymously.

 

If your organization delegates any functions related to PrimeTime Health Plan, please list of all delegates below.


The submitter of this attestation hereby attests on behalf of their Organization to the above requirements and certifies all training is complete.