CMS Fraud, Waste and Abuse Training Requirement for Medicare Advantage Participants

Medicare Advantage organizations are required to ensure that “first tier, downstream and related entities” complete CMS general compliance and fraud, waste and abuse (FWA) training.  Practices are considered to be downstream entities of Medicare Advantage organizations, and the CMS training module must be provided as written, without modification, to all employees of a downstream entity.

The memo from CMS states:

First tier, downstream and related entities and their employees can complete the general compliance and/or FWA training modules located on the CMS Medicare Learning Network (MLN).”

To minimize the burden on downstream entities, CMS permits the standardized training modules (from its website) to be incorporated into an organization’s existing compliance training materials or training systems, as long as the CMS training content is not modified (to ensure the integrity and completeness of the training).

To provide a convenience to our subscribers, we will provide the CMS general compliance and fraud, waste and abuse training (without modification) in the November 2015 Compliance Training module (and online E-Compliance Training module).

If you are not a subscriber, or prefer to access the CMS training module directly, you may locate it at:

Then, the title you are looking for is:

  • Medicare Parts C and D Fraud, Waste, and Abuse Training and Medicare Parts C and D General Compliance Training [ZIP, 2MB]”

This is a download, and once downloaded, users will not need Internet access to use it.

Certificate of Completion/Attestation of Training 

Medicare Advantage sponsors are required to validate that the general compliance and fraud, waste and abuse training requirements are met by their downstream entities.  CMS accepts validation in the form of certificates of completion, or an attestation confirming completion of appropriate training (i.e., training documentation).

If your practice participates in our E-Compliance (online) Training program: 
Each employee will have the option to print a certificate of completion following submission of his/her test answers.

If you provide training through the American Practice Advisor Compliance Training module:
Maintain employee training tests to serve as documentation of training completion.

If a Sponsor specifically requires the CMS certificate of completion (although not required by CMS):
Navigate to the last page of the CMS training module and complete the certificate with each employee’s name before printing the document.  (Directions to the document are provided in the previous section.)

Please contact Eagle Associates at (800) 7772337, or email if you require further clarification.