Compliance and Fraud, Waste and Abuse (FWA) Program, Training and Reporting for Providers and FDRs

Elderplan requires that all vendors and first tier, downstream and related entities (FDRs) adhere to our Compliance Program and our policies, procedures and standards of conduct, which are encompassed in our Elderplan Code of Conduct, or implement their own compliance policies, procedures and standards of conduct that meet federal and state requirements. Elderplan strongly encourages all vendors and FDRs to be regularly trained on Medicare and Medicaid Compliance and Fraud, Waste and Abuse (FWA). The Elderplan Code of Conduct and Federal Deficit Reduction Act Policy are provided here for reference and review by FDRs, vendors and other interested parties. Additionally, Elderplan has provided a link to the CMS Medicare Parts C and D Compliance and Fraud, Waste and Abuse Trainings to aid FDRs and vendors in providing comprehensive compliance and FWA training to their staff, if they do not have their own comparable training content.

Federal Deficit Reduction Act Policy

For more information on Medicare Parts C and D compliance and FWA program requirements applicable to Elderplan, visit the below link.

Chapter 9 and Chapter 21 Compliance Program Guidelines

FDRs have three (3) options for ensuring FDRs have satisfied the general compliance training requirement:

(1) FDRs can complete the general compliance and/or FWA training modules located on the CMS MLN. Once an individual completes the training, the system will generate a certificate of completion. The MLN certificate of completion will be accepted by Elderplan.

(2) FDRs can download and incorporate the content of the CMS standardized training modules from the CMS website into their organizations’ existing compliance training materials/systems.

(3) FDRs can incorporate the content of the CMS training modules into written documents for providers (e.g., provider guides, participation manuals, etc.).

Although the training content cannot be modified, CMS will allow modifications to the appearance of the content (i.e., font, color, background, format, etc.). Additionally, organizations may enhance or wrap around the CMS training content by adding topics specific to their organization or the employee’s job function.

Fraud, Waste and Abuse Training

Elderplan will accept either the CMS MLN system generated certificates of completion, or an attestation confirming that the organization has completed the appropriate compliance and FWA training. Attestations must include language specifying that the entity complies with CMS compliance and FWA training requirements, and, if choosing to implement option (2), the training provided includes CMS content without modification. Further, Medicare FDRs must maintain certificates or documentation of training completion and will furnish to Elderplan, upon request, certificates of training such as certificates of completion, training logs, system generated reports, spreadsheets, etc. All records of training must include at least employee names, dates of employment, dates of completion and passing scores (if captured) to clearly document training completion. Training records are subject to review and validation by Elderplan.

The records of trainings must be maintained for a period of no less than 10 years from the date the training is completed and in accordance with their written agreement with Elderplan.

Elderplan is committed to an environment where open, honest communications are the expectation, not the exception. If you would like to report a potential compliance issue or potential FWA, you have three options:

• Contact Elderplan Compliance Officer Candice Weatherly at 718-759-4260 or [email protected].
• Submit your question/concern electronically to the Elderplan Compliance and Ethics Hotline. To ensure confidentiality, the hotline is operated by a third-party vendor.
• Call the anonymous Elderplan Compliance and Ethics Hotline at 1-855-395-9169. To ensure confidentiality, the hotline is operated by a third-party vendor.

Elderplan has a strict non-retaliation and non-intimidation policy that protects any individual who reports a compliance concern in good faith. The policy applies to any employee, member, family member, first-tier, downstream and related entity, vendor or board member who reports a compliance or FWA concern.