How to Implement Fraud, Waste, and Abuse Training that Satisfies OIG Requirements

Training Requirements for Employees and Subcontractors

Who must be trained

You should train all employees, managers, executives, and governing board members, as well as subcontractors and vendors who touch billing, referrals, marketing, or claims. Include first-tier, downstream, and related entities, temporary staff, and high-risk roles such as coding, revenue cycle, case management, and network contracting.

Timing and frequency

Provide Fraud, Waste, and Abuse training at onboarding and refresh it on a regular cadence—commonly annually. Align timelines with payer contracts and program rules, which may specify completion within a defined period after hire or contracting. Update or assign focused modules whenever laws, policies, systems, or risk profiles change.

Role- and risk-based depth

Deliver a foundational module to everyone, then add role-specific content for clinical staff, coders, utilization management, sales and outreach, procurement, and leadership. Use real scenarios from your operations to make risks tangible and to reinforce Internal Compliance Programs and a culture of accountability.

Accountability and governance

Designate a compliance officer to oversee curriculum, approvals, and Training Completion Monitoring. Establish clear disciplinary consequences for non-completion and document remediation steps. Build training expectations into contracts with subcontractors and require periodic certifications to confirm adherence.

Key Content Areas in FWA Training

Code of conduct and reporting culture

Open with your code of conduct, non-retaliation policy, reporting channels (hotline, email, portal), and examples of when to seek guidance. Emphasize that early reporting protects patients, your organization, and the integrity of federally funded programs.

Core federal laws and program fraud risks

• False Claims Act: submitting or causing submission of false claims, reverse false claims, and whistleblower protections.
• Federal Anti-Kickback Statute: improper remuneration for referrals or business generation, including gifts, discounts, and arrangements with referral sources.
• Civil Monetary Penalty Law: beneficiary inducements, false statements, and other prohibited conduct.

Explain how these laws apply to everyday decisions—referrals, vendor relationships, marketing practices, and claims submission. Clarify exclusion screening responsibilities and the consequences of violations.

Medicaid and CHIP Compliance considerations

Address state-specific requirements, managed care contract provisions, encounter data integrity, prior authorization risks, and provider credentialing. Highlight documentation standards, overpayment identification and timely refund expectations, and reporting obligations to state agencies.

Operational risk areas and red flags

• Billing and coding: upcoding, unbundling, duplicate billing, medically unnecessary services, and altered documentation.
• Clinical and access risks: inappropriate denials/approvals, improper steering or marketing, and beneficiary inducements.
• Procurement and vendor risks: conflicts of interest, gifts, and high-risk contract terms.
• Data integrity: inaccurate rosters, encounter claims mismatches, and manipulated quality reporting.

Detection, response, and continuous improvement

Teach employees how to spot anomalies, preserve records, escalate concerns, and cooperate with investigations. Outline your corrective action process, from root-cause analysis to monitoring the effectiveness of remedial measures.

Methods of Training Delivery

eLearning for scale and consistency

Use interactive eLearning (with quizzes and branching scenarios) for consistent delivery across locations and subcontractors. Ensure accessibility, mobile compatibility, and language support to reach all audiences.

Live sessions for discussion and nuance

Supplement eLearning with live workshops or town halls to address complex arrangements, new risk areas, and Q&A. Record sessions and capture attendance to maintain a complete audit trail.

Microlearning and reinforcement

Reinforce key concepts with short refreshers, case spotlights, and manager-led huddles. Deliver just-in-time prompts during high-risk workflows like coding, prior authorization, or vendor onboarding.

Version control and change management

Maintain versioned curricula tied to policy updates and regulatory changes. Archive prior versions, note effective dates, and document approvals by compliance and legal reviewers.

Documentation and Employee Attestation

What to document

• Assignments and audiences (who was required to take which module and why).
• Delivery method, curriculum title, version, and effective date.
• Completion dates, scores, time-in-course, and attempts.
• Make-up training and remediation steps for late or failed completions.

Employee Training Attestation

Require signed attestations confirming the learner completed the module, understands the code of conduct, and knows how to report concerns. Use secure digital signatures and store attestations with the associated training record.

Subcontractor and vendor evidence

Collect certificates, rosters, or system exports from subcontractors. When relying on a vendor’s curriculum, obtain syllabi and confirm it covers required laws and your policies. Reserve audit rights in contracts to validate documentation.

Retention and audit readiness

Follow your record retention policy and applicable contractual or state requirements. Keep records orderly and exportable so you can rapidly demonstrate compliance during audits, investigations, or due diligence.

Monitoring Training Compliance

Key metrics and thresholds

• Assignment rate: percent of required population assigned to each module.
• Completion rate and time-to-complete: track against target timelines.
• Assessment outcomes: pass rates and questions frequently missed.
• Exception management: overdue counts and remediation timeliness.

Training Completion Monitoring in practice

Automate reminders, dashboards, and escalations. Provide leaders with roster-level visibility so they can intervene early. Use risk-based prioritization to focus on high-impact roles and subcontractors.

Continuous improvement loop

Analyze trends, investigate root causes for gaps, and update content and processes. Tie monitoring to audit results, hotline data, and corrective action plans to verify improvements are effective and sustained.

Utilizing OIG Training Resources

Leverage OIG guidance to benchmark your program

Use OIG compliance program guidance and educational materials to validate your curriculum, align with the seven elements of an effective compliance program, and benchmark expectations for training, monitoring, and response.

Integrate with payer and state obligations

Map OIG expectations to Medicare Advantage, Part D, Medicaid and CHIP Compliance requirements, and specific contract terms. Where requirements differ, adopt the most stringent standard and document your rationale.

From guidance to execution

Convert guidance into repeatable processes: defined ownership, versioned curricula, clear timelines, robust documentation, and proactive monitoring. Periodically reassess risks and refresh content so your program stays current and effective.

Conclusion

To implement Fraud, Waste, and Abuse training that satisfies OIG requirements, define who must be trained, cover the right laws and risks, deliver content effectively, capture airtight documentation and Employee Training Attestation, and run disciplined Training Completion Monitoring. Leverage OIG resources and align with payer and state rules to keep your Internal Compliance Programs both compliant and practical.

FAQs.

What are the required timelines for FWA training?

Timelines are set by program rules and contracts. A common standard is initial training at onboarding (or shortly after contracting for subcontractors) with annual refreshers thereafter. Some arrangements specify completion within a set window—often 30 to 90 days—plus retraining when laws, policies, or systems change. Confirm exact timelines in your payer contracts and state Medicaid or CHIP requirements.

How should organizations document employee training completion?

Maintain system reports showing assignments, completion dates, scores, time-in-course, delivery method, and curriculum version. Capture Employee Training Attestation with a dated signature acknowledging understanding of your code of conduct and reporting channels. Retain rosters and materials for live sessions, plus subcontractor certificates or exports. Ensure records are exportable for audits.

What federal laws must FWA training cover?

At minimum, address the False Claims Act, the Federal Anti-Kickback Statute, and the Civil Monetary Penalty Law. Explain exclusion screening, beneficiary inducement prohibitions, and overpayment obligations. Tailor examples to your operations and include any additional requirements from your contracts or state Medicaid and CHIP programs.

How can organizations access OIG training materials?

You can use publicly available OIG compliance program guidance and educational tools to shape your curriculum and benchmarks. Review these materials alongside your legal counsel, then translate them into organization-specific policies, training content, and monitoring procedures that reflect your risks and contractual obligations.