Blue Cross Blue Shield of Texas - Medicare Advantage Mandatory Provider Fraud, Waste and Abuse Training

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Medicare Advantage Mandatory Provider Fraud, Waste and Abuse (FWA) Training

Blue Cross and Blue Shield of Texas (BCBSTX) and Blue Medicare PPO are committed to compliance with the Centers for Medicare and Medicaid Services (CMS) requirements and to that end; we are committed to ensuring that our contracted providers remain in compliance. On December 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 (i.e., physician practices, facilities, DME providers, etc.) participating in a Medicare Advantage (Part C) network with Fraud Waste and Abuse training annually. CMS specifies that participation in this training is mandatory for anyone in the provider’s practice who may interface with a Medicare Part C beneficiary. BCBSTX will leave the decision as to who in the physician’s practice will require the training to the discretion of the physician or Compliance Officer. This rule was effective on January 1, 2009 and the training for 2009 must be completed by December 31, 2009 in order for providers to remain active in the Blue Medicare PPO (BMPPO) network in 2010.

This requirement grew out of an ongoing concern about the rising cost of health care combined with the overwhelming number of fraud, waste and abuse cases involving the Medicare program and its beneficiaries. BCBSTX/Blue Medicare PPO strongly supports this requirement because we believe that it is the right thing to do. To meet this requirement BCBSTX/Blue Medicare PPO will make its FWA training program for providers available on our website. To access the training, go to Medicare Advantage Mandatory Provider FWA Training. You will find the attestation at the end of the course. If you have already completed the FWA training provided by another Medicare Advantage plan sponsor, you may use that training to satisfy this requirement. Just go to the Medicare Advantage Mandatory Provider FWA Training, then scroll down and click on the link that states -
Providers who have already taken another Plan’s Part C and Part D training…
to take you directly to the attestation page. You must identify the source of the training on this attestation.

Providers who do not have internet access may request the hardcopy training/attestation by calling (713) 354-7685 for those providers in the Houston area and (915) 496-6600, Option 2 for those providers in the El Paso area. These providers will be required to fax their attestations to Blue Medicare PPO in order to receive credit for meeting the training requirement. The fax number will be on the attestation form you receive.

We recognize that since CMS requires that each Medicare Advantage Plan Sponsor make FWA training available to its participating providers you could be inundated with training requirement, depending on the number of Part C networks you are participating in. 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); or
Completion of a FWA training course offered by a hospital where you have admitting privileges; or
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; and
How and where to report potential FWA; or,

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; and
How and where to report potential FWA violations

Training must be completed between January 1, 2009 and October 31, 2009.

At the completion of the training BCBSTX/Blue Medicare PPO will require that the contracting physician or Compliance Officer complete our online certification attesting that all employees identified as requiring FWA training have completed such. 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 that was completed by each employee. These records must be maintained for a period of 10 years, which is the Medicare record retention period. In addition 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 office.

revised 9/2009