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Requirements How to Comply

General Compliance Education - Plan sponsors must ensure that general compliance information is communicated to their FDRs including their PBM as a first tier entity. The plan sponsor’s compliance expectations can be communicated through distribution of the Navitus Code of Conduct and/or compliance policies and procedures to FDRs’ employees. (Medicare Prescription Drug Benefit Manual Ch. 9 §50.3.1)

FWA Training - The PBM’s employees (including temporary workers and volunteers), governing body members, as well as FDRs’ employees who have involvement in the administration or delivery of Part D benefits must, at a minimum, receive FWA training within 90 days of initial hire (or contracting in the case of FDRs), and annually thereafter. PBMs must be able to demonstrate that their employees and FDRs have fulfilled these training requirements as applicable. (Medicare Prescription Drug Benefit Manual Ch. 9 §50.3.2)

  • Take the CMS Standardized General Compliance and FWA Training Modules, available at http://www.cms.gov/MLNProducts
  • Ensure that any of your employees, including temporary workers or volunteers, that support Navitus Medicare Part D programs complete  the training within 90 days of hire and annually thereafter.
  • Maintain records of any Medicare general compliance and fraud, waste, and abuse training and education taken by your employees for 10 years. The records must demonstrate the date of the training, the topic, attendance, and certificates of completion and/or test scores, if applicable. Examples of proof of training may include copies of sign-in sheets, employee attestations and electronic certifications from the employees taking and completing the training.
  • If you are “deemed” for FWA training, you do not need to take the CMS Standardized FWA training. Organizations are “deemed” if they have met the FWA certification requirements through enrollment into Parts A or B of the Medicare program or through accreditation as a supplier of DMEPOS. However, Navitus must still communicate general compliance information to its FDRs. Navitus provides General Compliance information to you and your employees through the following methods:
    • The FDR Compliance Guide;
    • This FDR page of the Navitus website.