Compliance, Fraud, Waste & Abuse Training
To assist all of our business partners (or FDR vendors) ArchCare is providing convenient access to the required attestation and the described training materials in order to comply with those described activities in CMS 42 CFR §422.503(b)(4)(vi)(A) and 42 CFR §423.504(b)(4)(vi)(A) (see attachments below) and sub-regulatory guidance found in the Prescription Drug Benefit Manual, “Chapter 9 – Part D program to Control Fraud, Waste and Abuse”.
Our policies and procedures require that our business partners complete and submit the ArchCare Annual Compliance Attestation, and implement all activities described in the attestation.
Questions or concerns related to these requirements may also be directed to: firstname.lastname@example.org. The training and compliance documents of our business partners (FDR vendors) may be utilized if meeting or exceeding the minimum requirements contained in those of ArchCare.
ArchCare Code of Conduct
The First-Tier, Downstream and Related Entities (FDR) Code of Ethics (Code) is focused on Medicare Part C & Part D along with Medicaid. The Code is an important segment of ArchCare’s overall Compliance Program. The Code provides FDR employees with the 1) ethical standards required in the delivery of Medicare and Medicaid products, 2) policy and procedure for reporting violations of the Code to the Medicare or Medicaid Compliance Officer and where applicable, to either the CMS designee, state agency, or law enforcement, 3) FDR’s commitment to comply with all applicable Federal and State regulations, and 4) details on disciplinary actions that can be imposed on an employee who fails to comply with the Code.
Compliance, Fraud, Waste and Abuse Training
The Compliance, Fraud, Waste, and Abuse training presentation is designed for First-Tier, Downstream and Related Entities (FDR) and addresses:
- The need to meet the CMS requirement for Medicare Advantage Organizations and Part D Sponsors to provide training materials to their First Tier, Downstream, and Related Entities.
- You and your current employees must complete this training, as well as all new hires upon joining your organization, and then annually thereafter.
- Maintain records of all training – this to include dates, method of training, materials used for training, identification of trained employees via sign-in sheets, employee rosters or other methods, etc.
- ArchCare, CMS, the NYS DOH or agents of CMS or NYS DOH may request such records to verify that training occurred.
The Compliance portion of the training presentation addresses the key components of ArchCare’s Medicare Compliance Program including:
- Written Policies and Procedures and Code of Ethics
- Medicare and Medicaid Compliance Officer, Compliance Committee
- Training and Education
- Effective Lines of Communication
- Enforcement of Disciplinary Standards (Well Publicized)
- Auditing and Monitoring
- Prompt and Effective Responses to Detected Offenses/Non-Retaliation
HIPAA Compliance Training
The HIPAA Compliance training is necessary for individuals who will be viewing PHI or PII. It is also necessary that we participate in this type of training annually to be able to provide our regulatory agencies the evidence to show each individual has completed a formal compliance HIPAA training program.
For questions or concerns, our business partners may also call Victor Fama, Director of Regulatory Affairs, 1‑917‑484‑5055.