Fraud, Waste, and Abuse Certificate: Requirements, Training, and Verification Guide

Training Requirements for Providers

Who must complete training

You must ensure that your workforce members who touch Medicare Advantage (Part C) or Part D work complete both general compliance training and Fraud, Waste, and Abuse (FWA) training. This includes your employees, temporary workers, governing body members, and any first tier, downstream, and related entity (FDR) staff involved in the administration or delivery of Parts C and D benefits. ([cms.gov](https://www.cms.gov/medicare/prescription-drug-coverage/prescriptiondrugcovcontra/downloads/chapter9.pdf))

What the certificate covers

The FWA certificate (or equivalent proof) confirms that learners can recognize FWA risks, understand reporting obligations, and know how to prevent, detect, and correct noncompliance under CMS Compliance Program Requirements. For general compliance, the certificate attests that learners reviewed your standards of conduct, reporting channels, and key policies tied to Medicare Parts A and B compliance expectations. ([cms.gov](https://www.cms.gov/medicare/prescription-drug-coverage/prescriptiondrugcovcontra/downloads/chapter9.pdf))

Timing and recurrence

General compliance training must be completed within 90 days of hire and annually thereafter; FWA training must be completed within 90 days of hire or contracting (for FDRs) and annually thereafter. Provide refresher or targeted training when job roles change, requirements change, or corrective action is needed. ([cms.gov](https://www.cms.gov/medicare/prescription-drug-coverage/prescriptiondrugcovcontra/downloads/chapter9.pdf))

Core Compliance Program Requirements

The seven required elements

• Written policies, procedures, and standards of conduct;
• Compliance officer, compliance committee, and high-level oversight;
• Effective training and education (including FWA);
• Effective lines of communication (confidential and accessible);
• Well-publicized disciplinary standards;
• Routine monitoring, auditing, and risk identification; and
• Prompt response to issues and corrective action.

These elements are mandated for Medicare Advantage organizations and Part D sponsors and flow to FDRs by contract under 42 CFR § 422.503(b)(4)(vi) and § 423.504(b)(4)(vi). ([law.cornell.edu](https://www.law.cornell.edu/cfr/text/42/422.503?utm_source=openai))

Accepted Training Methods

What CMS and plans accept

You may use the CMS Medicare Learning Network (MLN) standardized modules or your own equivalent program. CMS states that using its MLN module is optional; sponsors should accept it as meeting FWA training requirements, and organizations may integrate that content into their learning systems. ([cms.gov](https://www.cms.gov/medicare/prescription-drug-coverage/prescriptiondrugcovcontra/downloads/chapter9.pdf))

Examples you can use today

• MLN web-based training such as “Combating Medicare Parts C and D Fraud, Waste, & Abuse.”
• Plan-provided training that mirrors CMS content.
• Internal LMS courses mapped to CMS-required elements, with knowledge checks and certificates.

MLN delivers self-paced WBTs for providers and notes that CE credits aren’t provided; the FWA module is available at no cost. ([cms.gov](https://www.cms.gov/mln-web-based-training?utm_source=openai))

Verification and Attestation Process

How sponsors and providers verify completion

Maintain proof of completion for every learner. CMS recognizes multiple forms of evidence, including certificates of completion, employee attestations, and electronic certifications captured by your LMS or testing tool. ([cms.gov](https://www.cms.gov/medicare/prescription-drug-coverage/prescriptiondrugcovcontra/downloads/chapter9.pdf))

FWA Attestation

MA and Part D sponsors commonly collect an annual FWA Attestation from FDRs confirming completion of required training, distribution of standards of conduct/policies, exclusion screenings, and related oversight steps. Be prepared to submit your attestation and supporting provider training records upon request. ([quartzbenefits.com](https://quartzbenefits.com/providers/providers-medicare-advantage-resources/medicare-advantage-fdr-compliance/?utm_source=openai))

Training Documentation and Retention

What to keep in your provider training records

• Learner name, role, and NPI (if applicable);
• Training title (general compliance or FWA), delivery method, and content source (e.g., MLN);
• Completion date and, if applicable, test score;
• Certificate or LMS report; and
• Supervisor/learner attestation, if used.

Plan sponsors must keep records for 10 years; contracts flow this obligation to FDRs, so retain FWA and general compliance training records for 10 years and make them available to sponsors, CMS, HHS, or their designees upon request. ([law.cornell.edu](https://www.law.cornell.edu/cfr/text/42/422.504?utm_source=openai))

Training Frequency and Exemptions

Standard frequency

Provide general compliance training within 90 days of hire and annually after that. Provide FWA training within 90 days of hire/contract and annually, plus at key triggers like job changes, policy updates, noncompliance findings, or corrective actions. ([cms.gov](https://www.cms.gov/medicare/prescription-drug-coverage/prescriptiondrugcovcontra/downloads/chapter9.pdf))

Deemed status (exemptions)

Entities enrolled in Medicare Parts A or B or accredited as DMEPOS suppliers are deemed to have met the FWA training requirement only. Deeming doesn’t waive general compliance training—continue to complete it annually to satisfy 42 CFR § 422.503(b)(4)(vi)(C) and § 423.504(b)(4)(vi)(C). ([cms.gov](https://www.cms.gov/medicare/prescription-drug-coverage/prescriptiondrugcovcontra/downloads/chapter9.pdf))

Training Availability and Cost

Access and budget planning

The CMS Medicare Learning Network offers FWA and related courses online at no cost, making it a practical baseline option for teams and FDRs. While MLN doesn’t grant CE credits, it provides standardized content and a certificate of completion; organizations may also invest in internal or third‑party courses if they prefer enhanced features or customization. ([cms.gov](https://www.cms.gov/mln-web-based-training?utm_source=openai))

Conclusion

To earn and maintain a Fraud, Waste, and Abuse certificate, train the right people on time, use accepted content (such as MLN modules), verify completions with certificates or attestations, and retain provider training records for 10 years. Apply the seven CMS Compliance Program Requirements consistently, and leverage deemed status appropriately while still completing annual general compliance training. ([law.cornell.edu](https://www.law.cornell.edu/cfr/text/42/422.503?utm_source=openai))

FAQs.

What are the mandatory training requirements for the Fraud, Waste, and Abuse certificate?

At a minimum, you must complete general compliance training within 90 days of hire and annually, and FWA training within 90 days of hire/contract and annually. Training should also occur when roles or requirements change or when corrective action is needed. Providers enrolled in Medicare Parts A or B or accredited as DMEPOS are deemed to have met the FWA training requirement only; general compliance still applies. ([cms.gov](https://www.cms.gov/medicare/prescription-drug-coverage/prescriptiondrugcovcontra/downloads/chapter9.pdf))

How is FWA training verified and attested?

Verification relies on acceptable evidence such as certificates of completion, employee attestations, and LMS reports. Many plan sponsors also require an annual FWA Attestation from FDRs confirming required training and related compliance activities. Keep documentation readily available for audits or sponsor requests. ([cms.gov](https://www.cms.gov/medicare/prescription-drug-coverage/prescriptiondrugcovcontra/downloads/chapter9.pdf))

How long must FWA training records be retained?

Retain training documentation for 10 years to align with CMS record retention and audit-access requirements that sponsors flow down to FDRs via contract. Keep records accessible to CMS, HHS, sponsors, and their designees upon request. ([law.cornell.edu](https://www.law.cornell.edu/cfr/text/42/422.504?utm_source=openai))