Individuals or entities who have entered into direct contracts with CommunityCare to provide administrative or health care services in connection with MAPD plans CommunityCare sponsors or administers are "first-tier" with respect to CommunityCare. Individuals or entities who contract with a first-tier FDR to perform subcontracted or delegated services for CommunityCare's MAPD plans are considered "downstream" with respect to CommunityCare.

Examples of first-tier or downstream individuals or entities include physicians and physician groups; pharmacists and pharmacy staff; pharmacy benefit managers (PBMs); and administrative service providers who exercise decision-making authority on behalf of CommunityCare (e.g., outside claims reviewers/processors; clinicians performing utilization management or review; enrollment/disenrollment processors).

• Complete an acceptable General Compliance and Fraud, Waste and Abuse (FWA) training program
• Maintain evidence that training has been completed
• Complete and submit the required attestation to CommunityCare by December 31st

MAPD plan sponsors must validate that their FDRs have completed general compliance and FWA training annually. As one of CommunityCare's FDRs, you must complete an appropriate training program, maintain evidence that the training has been completed, and make that documentation available to CommunityCare upon request. Acceptable evidence includes individual certificates of completion or training logs that include employee names, dates of employment, dates of completion and evidence of passing scores (if captured).

• Complete the general compliance and FWA training located on the Medicare Learning Network (MLN) website (https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/Downloads/MedCandDGenCompdownload.pdf) and keep the system-generated certificates of completion; or
• Download and incorporate the content of the MLN training, without modification, into your existing compliance training program materials and keep appropriate training logs

Although FDRs who are enrolled into Medicare Parts A or B, or who are accredited DMEPOS suppliers, are deemed to have met the annual FWA training requirements, they are NOT exempt from Medicare's general compliance training requirement.

Individual FDRs (e.g., independent physicians/pharmacists) and authorized representatives of FDR entities (e.g., management staff of physician groups and PBMs) must complete an attestation once the annual general compliance and FWA training has been completed. You must submit the attestation by December 31st in order to be in compliance with CMS requirements.

• Link to Attestation