Tag Archive for: oig

Compliance is More than Training

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The following information provides a brief roadmap to achieving compliance, and is intended to help you understand the need to do more than employee training in order to avoid enforcement action from regulatory agencies.

Many practices view compliance training as the primary element for meeting regulatory requirements.  Although training is a key component, the reality is that compliance requires more than training.  Here are the basic major elements for ensuring compliance with any set of regulations:

Written Policies – Regulations, such as HIPAA and OSHA, require that you have written policies explaining your intent and process for meeting requirements.

Updates – Additionally, regulatory agencies require that you monitor for changes, new requirements, and new interpretations to ensure your policies remain current.

Training – All regulations include various requirements ranging from initial or new hire training to annual training on certain key elements.

Documentation – Records or documentation must be maintained.

Active Program – Having an active compliance program is a key element that you will not find specifically stated in a regulation, but can prevent the practice from being penalized if investigated. Regular audits help to ensure policies are being followed, and will ensure your compliance program remains active and relevant.

Note – These elements are provided for in Eagle Associates’ compliance programs. However, attention to provided updates, participation in employee training and use of included compliance tools is necessary to ensure your programs remain active.

New OIG Compliance Program Available!

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As a condition of enrollment in Medicare, Medicaid and/or the Children’s Health Insurance Program (CHIP), the Affordable Care Act requires providers to establish a compliance program to prevent fraud, waste and abuse.

While Eagle Associates has had an OIG Compliance Program available for many years, we have completely revised the program to provide a more complete and user-friendly compliance system. Please review the features of the OIG Compliance Program below and feel free to contact us to discuss how this program could benefit your practice.

Program Features

Our OIG Compliance Program includes the following benefits and services:

  • American Practice Advisor subscription, including an annual OIG Fraud & Abuse Prevention training module.
  • A complete review of various fraud, waste and abuse laws.
  • A written policy manual to address fraud and abuse prevention methods, such as screening procedures, auditing and monitoring policies, reporting and investigation procedures, disciplinary actions and more.
  • An Implementation & Review Guide to help you implement policies, and conduct an annual review of program elements.
  • OIG orientation materials for initial training.
  • Our live support feature provides your practice access to our Compliance Consultants, who will answer any questions that you have about your compliance program.

In addition, we have recently partnered with a company that offers a unique and powerful tool for internal audits of patient encounters, ICD-10 code look-ups, coding guidelines and more.  SpringSoft Medical offers their cloud-based program, Swiftaudit, to improve revenue and compliance through objective auditing procedures.  All data is securely stored and accessible only to your practice for review and documentation purposes.  This program is offered as an optional companion tool with the OIG Compliance Program at a substantial discount.

If you need assistance establishing an OIG compliance program, please contact us for more information at (800) 777-2337 or email:  info@eagleassociates.net.

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

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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) 777‑2337, or email info@eagleassociates.net if you require further clarification.