Reminder: Annual Medicare Compliance Training

Highmark requires Medicare first-tier, downstream and related (FDR) entities to complete annual compliance training.

This requirement applies to every individual who is associated with your practice or facility and works with Highmark’s Medicare Advantage and/or Medicare Part D Prescription Drug Plan (PDP) members and who fall into one of these categories:

• Employee
• Governing-body member
• Temporary worker
• Contractor
• Subcontractor
• Volunteer

Have you completed your training this year?

Highmark requires compliance training to ensure that all practices and facilities receiving Medicare dollars understand how to comply with the laws, regulations, guidelines, and policies for the Medicare program and how to prevent, detect, and correct Medicare fraud, waste, and abuse (FWA).

Compliance training must be completed:

• At the beginning of the individual’s employment, contract, or appointment: Within 90 days.
• During employment, contract, or appointment: Between Jan. 1 and Dec. 31 every year.

Where to go for training?

There are two main options for training:

• Online via the CMS Medicare Learning Network
• FWA training offered by your practice or facility

Important: Training programs must be reviewed in their entirety and documented by:

• Sign-in sheets
• Individual employee attestations
• Electronic certifications

The records must include:

• Time
• Attendance
• Topic
• Certificates of completion (if applicable)
• Test scores (if applicable)

Proof of training completion must be provided to Highmark upon request. Training records must be maintained for the period of the provider's contract with Highmark, plus an additional 10 years.

Are there any exceptions to these guidelines?

Yes. FDRs who have met the FWA training and education certification requirements through enrollment into Parts A or B of the Medicare program or through accreditation as a supplier of durable medical equipment, prosthetics, orthotics, and supplies are deemed to have met Highmark’s annual compliance training requirements.

If your practice or facility cares for Medicare-eligible patients, please share this article with your colleagues.