How to Deliver CMS-Compliant FWA Training for FDRs and Providers

CMS FWA Training Requirements Overview

Fraud, Waste, and Abuse (FWA) training is a core element of Medicare Parts C and D compliance. If you work with Medicare Advantage Plan Sponsors or operate as an FDR, you must ensure staff who touch Medicare business complete both general compliance and FWA training that aligns with CMS Fraud Waste and Abuse Training Standards.

Who must be trained

• Employees, temps, volunteers, and contractors who perform work for Medicare Parts C or D lines of business.
• First-Tier Downstream Related Entities (claims administrators, PBMs, call centers, marketing firms, and Durable Medical Equipment Suppliers) supporting a Sponsor’s Medicare operations.

When training is due

• Within 90 days of hire or contract effective date.
• Annually thereafter, with completion tracked to due dates and reassignments for late learners.

What effective training covers

• FWA definitions, red flags, and reporting channels, including non-retaliation protections.
• Roles and responsibilities under an effective compliance program for Medicare Parts C and D Compliance.
• Realistic scenarios for your business model (e.g., pharmacy adjudication, DME delivery, sales/marketing).

Deemed Compliance for Medicare Providers

Many Medicare-enrolled providers and suppliers are “deemed” to have met the FWA training requirement. This typically includes physicians, hospitals, and Durable Medical Equipment Suppliers that are actively enrolled in Medicare.

What deemed status covers

• Deemed status applies to the FWA training component only.
• Plan Sponsors may still require general compliance training and must distribute Standards of Conduct and reporting instructions to all applicable providers and FDRs.

How to operationalize deemed status

• Collect and maintain the provider’s legal name, NPI, TIN, and evidence of current Medicare enrollment.
• Document how deemed providers receive the Sponsor’s Standards of Conduct and compliance reporting hotline information.
• Flag deemed entities in your roster so they are excluded from FWA assignments but included in required general compliance outreach.

Utilizing CMS Web-Based Training Module

The CMS Web-Based Training Module, offered through Medicare Learning Network Modules, remains a widely accepted way to meet FWA training standards. It can be assigned as-is or paired with Sponsor-specific materials for job relevance.

Practical delivery steps

• Decide whether to deploy the CMS module directly or import equivalent content into your LMS.
• Assign the course to targeted populations only (e.g., non-deemed FDR staff who handle Medicare Part C or D work).
• Require a passing score on a knowledge check and capture a certificate or LMS completion record.

When to customize

• Add short, role-based H3/H4 micro-lessons (e.g., pharmacy prior authorization red flags, DME delivery confirmation controls).
• Embed your reporting hotline, privacy reminders, and Sponsor-specific scenarios without altering the core FWA concepts.

Plan Sponsors' Role in Training Enforcement

Medicare Advantage Plan Sponsors are accountable for ensuring FWA and general compliance training is completed across their FDR network. Strong enforcement blends contract requirements, monitoring, and escalation.

Contract and delegation essentials

• Include explicit FWA and general compliance training clauses in FDR agreements, with timelines and evidence requirements.
• Define consequences for non-compliance (corrective action plans, payment holds, or termination of delegation).

Oversight and escalation

• Perform pre-delegation due diligence to validate training programs and records.
• Monitor completion rates monthly during peak cycles and quarterly thereafter; escalate chronic gaps to leadership.
• Use risk-based sampling for high-impact entities (e.g., PBMs, claims processors, Durable Medical Equipment Suppliers).

Best Practices for Training Documentation

Clear, retrievable records are as important as the training itself. Strong documentation enables swift responses to CMS, auditors, or Sponsor oversight teams.

Core artifacts to maintain

• Rosters showing learner name, role, employer (Sponsor or FDR), and Medicare business function.
• Completion proof: LMS records, certificates, scores, and attestations to the Standards of Conduct.
• Content evidence: syllabus, learning objectives, revision dates, and the assessment used.

Training Documentation Retention

• Retain training records for 10 years, consistent with CMS record-retention expectations.
• Store evidence securely; restrict PII access and maintain an auditable chain of custody for exports.

Audit-ready organization

• Index evidence by FDR, training year, and training type (FWA vs. general compliance).
• Maintain a “deemed status” register with NPI and enrollment verification for providers and suppliers.

Updating Training Annually

Annual updates keep content accurate and engaging while aligning with evolving Fraud Waste and Abuse Training Standards. Treat the refresh as a mini product release.

Update cycle

• Q4: Review CMS guidance, enforcement trends, and prior audit findings; finalize revisions.
• Q1: Publish assignments, set due dates, and launch communications for FDRs and internal staff.

Content refresh priorities

• Incorporate new case studies, high-risk scenarios, and clarifications on reporting obligations.
• Adjust role paths so learners see only what’s relevant to their Medicare functions.

Monitoring and Auditing Training Compliance

Monitoring shows whether training is finished on time; auditing tests whether it is effective and properly evidenced. Both are required disciplines for reliable oversight of FDRs.

Monitoring metrics

• Assignment coverage: percent of in-scope personnel with an active training assignment.
• On-time completion rates and average days-to-complete by FDR and function.
• Open corrective actions and recurrence rate after remediation.

Audit procedures

• Validate learner populations against active rosters and contracts.
• Sample completion records; cross-check names, dates, scores, and certificates.
• Review content against Medicare Learning Network Modules for equivalency and accuracy.

Common findings and fixes

• Mismatched rosters and training assignments—establish an HR/LMS nightly feed.
• Missing evidence for deemed providers—create a standardized NPI/enrollment verification log.
• Static content—introduce annual scenario updates tied to recent risk events.

FAQs

What are CMS requirements for FWA training completion?

Individuals who support Medicare Parts C or D work must complete FWA training and general compliance training aligned to CMS standards. Training must explain FWA risks, how to report concerns, and expectations under the Sponsor’s compliance program, with proof of completion retained for audit.

How often must FWA training be conducted for FDRs?

Assign FWA training within 90 days of hire or contract start and repeat it every year. Track due dates, send reminders, and ensure late learners are promptly reassigned to maintain continuous compliance.

Are Medicare providers exempt from CMS FWA training?

Medicare-enrolled providers and suppliers are generally “deemed” to have met the FWA training requirement. However, Plan Sponsors may still require general compliance training and must provide Standards of Conduct and reporting instructions to these entities.

What documentation is required to prove FWA training compliance?

Maintain rosters, completion records or certificates, assessment results, and signed attestations to Standards of Conduct. Keep content outlines and version histories, and retain all evidence for 10 years, including logs showing deemed providers’ Medicare enrollment status.