CMS General Compliance & Fraud, Waste and Abuse Training

Physician Training Requirement

The Centers for Medicare and Medicaid Services (CMS) requires initial and annual Compliance and Fraud, Waste and Abuse (FWA) training for entities that provide health, prescription drug, or administrative services to Medicare Advantage (MA) or Prescription Drug Plan (PDP) beneficiaries on behalf of a MA or PDP health plan.

Providers and their staff that provide care to beneficiaries enrolled in a Medicare Advantage health plan contracted with Brown & Toland are required to complete the Compliance and Fraud, Waste and Abuse training posted below within 30-days of contract and annually thereafter before the end of the calendar year.

Effective January 1, 2016, all first-tier, downstream and related entities (FDR) are required by CMS to utilize the general compliance and fraud, waste and abuse training content located on the CMS Medicare Learning Network (MLN) to satisfy the General Compliance and FWA training requirements.

The following guidance remains unchanged:

  • All FDR associates supporting Medicare business are required to complete both General Compliance and FWA Training.
  • Trainings must occur within 30 days of hire/contract, and annually thereafter.
  • Documentation must be maintained to support the completion of General Compliance Training and FWA Training.
  • All documentation must be maintained for a minimum of 10 years.

Training Options:

1.     Brown & Toland network providers can complete the general compliance and FWA web-based training modules located on the CMS MLN.

  • The system will generate a certificate of completion once the training has been completed.
  • The MLN certificates of completion will be accepted by Brown & Toland.
  • To access the training materials through the CMS MLN, follow the training materials here:

    CM's Web-Based Medicare Learning Network (MLN) Access Guide

 2.     Brown & Toland network providers can complete the general compliance and FWA training through review of the CMS training slides provided below.

You may access the CMS Training slides here: 
 
  • FDRs who have met the FWA certification requirements through enrollment into Parts A or B of the Medicare program or through accreditation as a supplier of DMEPOS are deemed to have met the FWA training and education requirements.  No additional documentation beyond the documentation necessary for proper credentialing is required to establish that a provider is deemed.
  • However, participation in Medicare Parts A and B does not deem completion of the “Medicare Parts C and D General Compliance Training”.  You must still actively complete review of this training within 30-days of contract and on an annual basis thereafter.
  • A signed Brown & Toland General Compliance & FWA Training Attestation will be accepted by Brown & Toland.  You should keep the signed attestation and will be required to provide it at request to demonstrate completion of training in the event of an audit by CMS. 

The attestation form can be found here: Compliance FWA Training Attestation - Provider

Reporting Compliance Concerns to Brown & Toland

If you have any compliance concerns, such as HIPAA or patient privacy violations or instances of fraud, waste, and abuse, you may communicate those concerns directly to Brown & Toland's Privacy & Compliance Program Officer or use our anonymous compliance reporting system.

Contact Brown & Toland

You may contact Brown & Toland's Privacy & Compliance Program Officer, Rebecca Lim by one of the following methods:

Phone: 415.972.4291
Email: rlim@btmg.com
U.S. Mail: 

   Brown & Toland Physicians
   P.O. Box 72710
   Oakland, CA 94612-8910
   Attn: Compliance Department

Make an anonymous report

To communicate compliance concerns to Brown & Toland anonymously, contact our third-party hotline service EthicsPoint.

Anonymous reports may be submitted to EthicsPoint by using one of the following methods:

     Online: Go to www.brownandtoland.ethicspoint.com and select the blue "make a Report" tab.  The EthicsPoint Web site is secure and is not part of the Brown & Toland Physicians website.

     Phone: Call EthicsPoint toll-free at 888.201.7305.

The information you provide will be sent by EthicsPoint to Brown & Toland on a totally confidential and anonymous basis if you so choose.

For additional questions regarding this training, please contact the Physician Relations Department at physicianrelations@btmg.com or call 415.972.4350.