Implementing ATI Health Care FWA Posttest: Training, Monitoring, and Documentation

FWA Training Requirements and Content

Begin by defining who must complete training under Medicare Advantage FWA regulations and your FDR compliance policies. Include employees, leaders, clinicians, temps, volunteers, board members, contractors, and all first tier, downstream, and related entities (FDRs). Align scope and depth to CMS audit requirements and your risk profile.

Cover the essentials: definitions of fraud, waste, and abuse; common schemes and red flags; accurate billing and claims integrity; marketing and beneficiary protections; conflicts of interest; overpayments; record retention; non-retaliation compliance policies; reporting obligations; vendor oversight; and exclusion list monitoring responsibilities.

Use the ATI Health Care FWA Posttest to verify comprehension. Build scenario-based questions mapped to learning objectives, set a clear passing threshold (for example, 80%), enable targeted remediation for missed topics, and randomize items to prevent answer sharing. Capture attempt count, time stamps, and version control for strong evidence.

Collect FWA training attestations immediately after completion. Record the learner’s name, role, entity, date, module ID, acknowledgment statement, e-signature, and posttest score. This pairing of attestation and assessment demonstrates both participation and effectiveness during CMS audit requirements reviews.

Delivering Effective FWA Training

Deliver training at onboarding and at least annually, with role-based assignments for claims, enrollment, pharmacy, clinical, and vendor management teams. Use your LMS to automate enrollments, reminders, and escalations for overdue learners, including FDRs.

Engage learners with microlearning, brief videos, interactive branching scenarios, and knowledge checks drawn from real incidents. Keep modules concise, plain-language, and accessible, with translation and offline options for non-desk staff.

Embed frequent knowledge checks that mirror posttest difficulty, then compare pretest and posttest results. Use item analysis to identify high-miss questions and update content quickly so training stays aligned to evolving risks and CMS audit requirements.

Document attendance and participation in live sessions with sign-in sheets or digital badges, and immediately issue FWA training attestations. Ensure managers verify completion and reinforce expectations in team meetings.

Retaining FWA Training Documentation

Maintain training records for at least 10 years, or longer if contracts or state rules require. Ensure records are searchable, tamper-evident, and retrievable within audit time frames to satisfy CMS audit requirements.

Retain completion rosters, date/time stamps, module and posttest versions, scores, remediation notes, certificates, curricula, facilitator guides, policy acknowledgments, and communications announcing training. Keep audit trails for any updates to content or learner status.

For FDR oversight, preserve evidence of their equivalent training, FWA training attestations, policies, and monitoring results. Store exclusion list monitoring logs (pre-hire/contract and monthly thereafter) for employees, providers, and FDRs to demonstrate proactive screening.

Use system controls: unique learner IDs, immutable audit logs, and report exports by population, entity, and timeframe. Map each report to the CMS audit requirements you expect to encounter so production during an audit is fast and complete.

Reporting and Investigating FWA

Offer multiple intake channels—hotline, secure web form, email, and open-door options—and publicize them widely. Allow anonymous reporting and emphasize your non-retaliation compliance policies in every communication and training module.

Standardize investigations: log intake, triage severity, preserve evidence, assign a conflict-free investigator, plan and conduct interviews, analyze data, and document findings. When substantiated, apply proportional discipline, restitution, and corrective action plans with clear ownership and due dates.

Define escalation criteria for external notifications to plan sponsors, regulators, or law enforcement. Track commitments, verify implementation of corrective action plans, and conduct effectiveness checks to ensure issues do not recur.

Close the loop by sharing de-identified trends with leaders and staff. Feed lessons learned back into training updates and the ATI Health Care FWA Posttest question bank to continuously strengthen prevention.

Compliance Program Elements Overview

• Standards, policies, and code of conduct that set clear expectations.
• Active Compliance Officer and committee with authority and resources.
• Effective training and education, including role-based FWA modules.
• Open lines of communication and safe, accessible reporting channels.
• Well-publicized disciplinary standards and positive incentives.
• Risk-based auditing and monitoring, including exclusion list monitoring.
• Prompt response to issues and sustainable corrective action plans.

Periodically reassess these elements against Medicare Advantage FWA regulations, FDR compliance policies, and CMS audit requirements. Document every change and communicate updates promptly to affected teams and FDRs.

Roles and Authority of the Compliance Officer

Position the Compliance Officer with organizational independence, direct access to the CEO and Board, and sufficient budget and staff. This role must have unrestricted access to people, processes, systems, and records.

Core responsibilities include risk assessment, policy stewardship, training oversight, FDR oversight, case management, and audit readiness. The officer ensures reporting channels are effective and that non-retaliation compliance policies are understood and enforced.

Grant explicit authority to pause risky activities, hold payments, or require operational changes when potential FWA is identified. The Compliance Officer also approves corrective action plans and verifies their effectiveness before closure.

Maintain governance artifacts—committee charters, agendas, minutes, dashboards, and escalations—to evidence oversight and timely decision-making during CMS audit requirements reviews.

Maintaining Confidential and Safe Reporting Channels

Provide 24/7 reporting options that are easy to find and use for employees, providers, vendors, and FDRs. Support anonymity, language access, and accommodations for individuals with disabilities.

Protect confidentiality end-to-end and reinforce non-retaliation compliance policies through training, onboarding, and leadership messages. Require managers to route concerns promptly and prohibit informal “issue filtering.”

Operate a robust intake and triage process with defined service levels, risk scoring, and escalation rules. Track channel usage, cycle times, substantiation rates, and repeat-issue trends to guide resource allocation and prevention.

Continuously monitor patterns across hotline data, audits, and operational metrics. Use insights to refresh training content, adjust the ATI Health Care FWA Posttest, and target audits where risk is rising. Together, training, monitoring, and documentation create a defensible, prevention-first program.

FAQs

What documentation is required for FWA training retention?

Retain completion rosters, date/time stamps, module and posttest versions, scores, remediation notes, FWA training attestations with e-signatures, certificates, curricula and facilitator guides, policy acknowledgments, communications announcing training, and system audit logs. For FDRs, keep their equivalent records plus oversight evidence and exclusion list monitoring results.

How often must FWA training be conducted?

Conduct FWA training at onboarding and at least annually for employees and FDRs, with ad hoc refreshers when laws change, risks increase, major incidents occur, or job duties shift. Reinforce critical topics through brief, periodic microlearning between annual cycles.

Who can report potential FWA incidents?

Anyone connected to your operations—employees, clinicians, contractors, FDRs, vendors, members, and caregivers—should be able to report concerns. Provide anonymous options and make reporting channels visible across facilities, intranet pages, and vendor communications.

What actions does the Compliance Officer take after a FWA report?

The Compliance Officer acknowledges receipt, triages risk, preserves evidence, and assigns an impartial investigator. They oversee fact-finding, determine outcomes, implement corrective action plans and discipline as needed, decide on external notifications, and verify effectiveness before closing the case and updating training where appropriate.