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Coventry Medicare FDR Training & Education

Welcome Medicare FDRs!

We’re pleased to announce that Aetna’s acquisition of Coventry Health Care, Inc. is now complete. Aetna and Coventry, as a combined organization, share a commitment to creating mutually beneficial relationships with our First Tier, Downstream and Related Entities (FDRs). If you have already completed Aetna’s 2013 general compliance and fraud, waste, and abuse (FWA) training, you may disregard this training. If you have not completed Aetna’s training, you should proceed as prescribed below.

As communicated to you through a separate notice, Medicare First Tier, Downstream, and Related entities (“FDRs”) are required to complete certain training courses based on the Centers for Medicare & Medicaid Services (“CMS”) regulation and/or our company policy. As a result, you, your entity, any downstream and/or related entities under your direction and in several cases your individual employees who are assigned to work on our Medicare business, must complete a number of requirements. This training and education must be completed initially, within 90 days of hire and at least annually thereafter. Participation in this training is mandatory for all your employees, downstream and related entities who are assigned to work on our Medicare business. If areas of noncompliance are determined including, but not limited to, refusal to complete the required training and education, enforcement actions may be taken to both cure the deficiency and prevent future occurrences. Enforcement actions, such as corrective action plans and/or contract termination, may vary depending upon the severity of the issue.

Please be advised that you are required to maintain evidence of completion (e.g., employee training records, CMS certificate of completion, etc.)  for no less than ten (10) years. We and/or CMS may request evidence of completion from you for these courses.

Please review the course information below and complete the training and education as described.

Downloading instructions, including an explanation of which type of download is suited for your needs (i.e. Stand-Alone versus LMS), is available after the list of courses below. 
 

COURSES




GENERAL COMPLIANCE AND FRAUD, WASTE, AND ABUSE

Code of Conduct

2013 General Compliance and FWA Training

LMS - Zip File  

 


You and/or your organization must complete general compliance training. In addition, you must complete the FWA portion of the training unless you are deemed to 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.

You must provide general compliance training to all of your employees, downstream, and related entity arrangements who are assigned to work on our Medicare business initially upon hire and annually thereafter. You must also provide FWA training, initially upon hire and annually thereafter, to all your employees, downstream and related entity arrangements who are assigned to work on our Medicare business unless these individuals are deemed to have met FWA certification requirements as described above. In addition, your organization must provide either Aetna’s Code of Conduct (“COC”) or your own equivalent COC to all of your employees, downstream, and related entities who are assigned to work on our Medicare business initially upon hire or contract commencement and annually thereafter.

Participation in training is required for your employees, downstream, and related entity arrangements who are assigned to work on our Medicare business.  To comply with this requirement, we have provided the 2013 CMS Medicare Parts C & D Fraud, Waste, and Abuse Training and General Compliance Training for your use.  As part of this training, your organization (regardless of deemed status) must also provide the Aetna Code of Conduct (“COC”).  Both the training document and Aetna’s COC are available for download through the links on the left.  Note: The LMS zip file is designed to work within a Learning Management System where completion data sourcing, and/or bookmarking is tracked (only applicable to entities with LMS).  You and/or your organization must complete general compliance training.  In addition, you must complete the FWA portion of the training unless you are deemed to 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.  Those parties deemed to have met the FWA training through enrollment into CMS' Medicare Program do not need to complete Part 1: Medicare Parts C and D Fraud, Waste, and Abuse Training, as outlined within the training documents, but should review Part 2: Medicare Parts C & D Compliance Training. 

You may use either our General Compliance and FWA Training and COC or substitute equivalent versions to satisfy these training requirements. Regardless of the training used, it must be completed initially, within 90 days of hire and at least annually thereafter and you must retain evidence of completion. This evidence may be in the form of attestations, training logs, or other means determined by you to best represent fulfillment of your obligations. For convenience, certificates of completion are provided as the last slides of the 2013 CMS Medicare Parts C & D Fraud, Waste, and Abuse Training and General Compliance Training. You must also ensure that any of your downstream or related entities complete these training requirements for their employees and subcontractors, as well.


REPORTING MECHANISMS


Reporting Mechanisms

 


CMS requires a system that fosters effective lines of communication between you and our company, regarding how you should report compliance concerns and suspected or actual misconduct. As a combined company, Aetna’s reporting mechanisms are in place for your use, as necessary, such as the AlertLine: 1 (888) 891-8910. These methods are outlined in the Reporting Mechanism document found through the link on the left. Please download this poster for distribution within your organization as appropriate. We have adopted and enforce a zero-tolerance policy for retaliation or retribution against anyone who reports suspected misconduct.


EXCLUSION LISTS


CMS requires that you, your employees, downstream and related entities and their employees are not on any of the below lists while servicing Coventry’s Medicare product lines:

• Office of Inspector General (OIG) LEIE Exclusion List 

             http://oig.hhs.gov/exclusions/index.asp

 • General Services Administration (GSA) EPLS Debarment List
Please ensure that these lists are checked initially upon hiring/contracting and then monthly by you, your downstream and related entities. Parties found on these lists must be immediately removed from work related directly or indirectly to the company’s Medicare business.


DOWNSTREAM AND RELATED ENTITY OVERSIGHT


CMS requires that you, your organization, any of your downstream and related entities maintain compliance as required by their guidance while you are servicing our Medicare products. If you utilize downstream and related entities, you must ensure that proper oversight is conducted through ongoing monitoring processes and annual audits.

A downstream entity is defined as any party that enters into a written arrangement, acceptable to CMS, below the level of the arrangement between the Sponsor and the first tier entity. These written arrangements continue down to the level of provider of both health and administrative services.

A related entity is defined as any entity that is related to the Sponsor by common ownership or control and a) performs some of the Sponsor’s management functions under contract or delegation; b) furnishes services to Medicare enrollees under an oral or written agreement, or c) leases real property or sells materials to the Sponsor at a cost of more than $2500 during a contract period. 42 CFR 423.501


OFFSHORE OPERATIONS


Offshore operations are typically contractually prohibited by Coventry. You must not engage in offshore operations for Coventry-related Medicare business without the expressed consent of an authorized company representative.

If you engage in, or utilize subcontractors engaged in, offshore subcontracting that involves receiving, processing, transferring, handling, storing, or accessing PHI and the arrangement is approved by our company, you are subject to reporting requirements to alert CMS of these activities and therefore must be reported to us before utilizing them.


FREQUENTLY ASKED QUESTIONS

FAQ - PDF
A list of frequently asked questions (FAQs) is available for your reference through the link on the left. If you have additional questions not addressed by the FAQs, please feel free to email Coventry’s FDR Governance personnel at corpcompliance@cvty.com.

Please be reminded this training must be completed within 90 days of hire/contracting and annually thereafter AND you must maintain evidence of completion for all of the courses above for no less than ten (10) years. Coventry and/or CMS may request evidence of completion from you and/or your downstream entities for these training and education requirements.



Downloadable Materials

The training can be completed on this website, downloaded to an individual(s) computer(s) or you can download the training into your own eLearning tool. You are required to download the LMS zip files before running them. If you attempt to open the course instead of saving and extracting, you may not be able to run it.

Which version should I download?

Two versions are available for download: Stand-Alone (using links to the actual documents above) or LMS.

- The Stand-Alone version is meant to run on a single computer without the use of a LMS. This version will not track any completion data, scoring, and/or bookmarking. To utilize this version of training simply click on the document link.

- The LMS version is designed to work within a Learning Management System, where completion data, scoring, and/or bookmarking is tracked.

Instructions for downloading and running on an LMS for those that have a Learning Management System within their organization 

Clicking on the LMS link allows you to save the course to your LMS or network.

1. Once you save the file, you may need to unzip before transferring to the location of your LMS files.
2. The imsmanifest.xml file is located in the root directory of the course file. You will need this to load your course into your LMS.
3. You should use the index_lms.html file or index.htm to launch your course.

Important: Be sure to turn off any popup blockers. These will interfere with launching the course.


Minimum Requirements

Minimum requirements for running the courses:

- Flash 7 or higher

- Web browser, (IE 7 or higher recommended)

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