The Centers for Medicare & Medicaid Services (CMS) requires Medicare Advantage (MA) Organizations and Part D Plan Sponsors, including UnitedHealthcare, to annually communicate specific Compliance and FWA requirements to their “first tier, downstream, and related entities” (FDRs). FDRs include contracted physicians, health care professionals, facilities and ancillary providers, as well as delegates, contractors, and related parties. As a delegate that performs administrative or health care services,CMS and other federal or state regulators require that you and your employees meet certain FWA and general compliance requirements.
FDRs are expected to have an effective compliance program, which includes training and education to address FWA and compliance knowledge. As of Jan. 1, 2019, FDRs are no longer required to complete the specific CMS FWA training modules or retain documentation of the training.
However, UnitedHealthcare’s expectation remains that FDRs, and their employees, are sufficiently trained to identify, prevent and report incidents of non-compliance and FWA. This includes temporary workers and volunteers, the CEO, senior administrators or managers, and sub delegates who are involved in or responsible for the administration or delivery of UnitedHealthcare MA or Part D benefits or services.
We have general compliance training and FWA resources available at unitedhealthgroup.com. The required education, training, and screening requirements include the following:
What You Need to Do
Provide a copy of your own code of conduct, or the UnitedHealth Group’s (UHG’s) Code of Conduct at unitedhealthgroup.com > About > Ethics & Integrity > UnitedHealth Group’s Code of Conduct. Provide the materials annually, and within 90 days of hire for new employees.
Maintain records of distribution standards (i.e., in an email, website portal or contract) for 10 years. We, or CMS, may request documentation to verify compliance.
What You Need to Do
Provide FWA and General Compliance training to employees and contractors of the FDR working on MA and Part D programs.
Administer FWA and General Compliance training annually and within 90 days of hire for new employees.