Compliance/Fraud Waste and Abuse (FWA) Program, Training and Reporting
Welcome to the Elderplan Compliance and Fraud Waste and Abuse (“FWA”) Program, Training, and Reporting page. This section provides valuable information about Elderplan’s Compliance/FWA Program (also referred to as policies, procedures and standards of conduct herein) for interested parties, including its compliance requirements for individuals and entities with whom Elderplan does business.
Elderplan requires that all employees and other parties who interface with any government program line of business on behalf of Elderplan, such as our Medicare and/or Medicaid plans, comply with our Compliance Program. Elderplan vendors and Medicare first tier, downstream and related entities (FDRs) that provide administration or health care services under contract with Elderplan must adhere to Elderplan policies, procedures and standards of conduct, which are encompassed in our MJHS/Elderplan Code of Conduct and Policy Pursuant To The Federal Deficit Reduction Act of 2015, or implement their own compliance policies, procedures and standards of conduct, which may be in the form of a code of conduct, that meet federal and state requirements. Further, vendors and FDRs must ensure that their employees and agents are trained on and held responsible for adherence with these compliance policies, procedures and standards of conduct. The MJHS/Elderplan Code of Conduct and Policy Pursuant To The Federal Deficit Reduction Act of 2015 and additional key accompanying documents are provided here for review by interested parties and especially for vendor and FDRs’ Executive Managers for use in adhering to the Elderplan/FWA policies, procedures and standards of conduct and/or to develop their own comparable compliance program documents.
For more information on Medicare health plan compliance/FWA program requirements applicable to Elderplan, our vendors and FDRs may visit the below link.
Sponsors and/or FDRs will have three (3) options for ensuring FDRs have satisfied the general compliance training requirement:
(1) FDRs can complete the general compliance and/or FWA training modules located on the CMS MLN. Once an individual completes the training, the system will generate a certificate of completion. The MLN certificate of completion will be accepted by Elderplan.
(2) Sponsors and FDRs can download and incorporate the content of the CMS standardized training modules from the CMS website into their organizations’ existing compliance training materials/systems.
(3) Sponsors and FDRs can incorporate the content of the CMS training modules into written documents for providers (e.g. Provider Guides, Participation Manuals, etc.).
Although the training content cannot be modified, CMS will allow modifications to the appearance of the content (i.e. font, color, background, format, etc.). Additionally, organizations may enhance or wrap around the CMS training content by adding topics specific to their organization or the employee’s job function.
Elderplan will accept either the MLN system generated certificates of completion, or, an attestation confirming that the organization has completed the appropriate compliance and FWA training. Attestations must include language specifying that the entity complies with CMS compliance and FWA training requirements, and, if choosing to implement option (2), the training provided includes CMS content without modification. Further, Medicare FDRs must maintain certificates or documentation of training completion and will furnish to Elderplan, upon request, certificates of training such as certificates of completion, training logs, system generated reports, spreadsheets, etc. All records of training must include at least employee names, dates of employment, dates of completion and passing scores (if captured) to clearly document training completion. Training records are subject to review and validation by Elderplan.
The records of trainings must be maintained for a period of no less than 10 years from the date the training is completed and in accordance with their written agreement with Elderplan.
To report Ethics, Compliance and FWA Issues to the Elderplan Health Plan Compliance Officer:
To report to the MJHS Corporate Compliance Officer:
To report anonymously 24 hours a day/7 days a week:
MJHS and Elderplan Compliance Hotline at 1-855-395-9169