FAQs: Completing the General Compliance and Fraud Waste and Abuse training, education, and provider attestation form.
- Why is a General Compliance and FWA Attestation required to be submitted to CHPW?
Community Health Plan of WA (CHPW) is required by contract with the Centers for Medicare & Medicaid Services (CMS) and the Washington State Health Care Authority (HCA) to ensure its contracted provider network completes General Compliance and Fraud, Waste, and Abuse (FWA) Training, within 90 days of contract, and annually thereafter. CHPW is required to maintain evidence that its contracted providers have completed training and must make available to the applicable state and federal agency, upon request.
- If your group is contracted with Medicare A or B, do you need to submit an Attestation?
As stated by CMS, there is one exception to the FWA training and education requirement. Regulations effective June 7, 2010 implemented a “deeming” exception which exempts Providers who are enrolled in Medicare Part A or B from annual FWA training and education. Therefore, if an entity or an individual is enrolled in Medicare Part A or B, the FWA training and education has already been satisfied and your Attestation would only apply to General Compliance.
- Who is required to receive this training?
All staff -- including your CEOs, senior leaders, managers, clerical/admin staff, physicians and other clinical staff.
- How often is a General Compliance and FWA (GCFWA) training required?
CMS requires General Compliance and Fraud, Wastes, and Abuse (GCFWA) training to be complete at least once a year and be made part of the orientation process for new employees. Note: See deeming exception for FWA in second bullet.
- When do we need to submit a GCFWA Attestation to CHPW?
New CHPW Providers: Within 90 days of a fully executed contract and annually thereafter.
Established Network Providers: If you have not submitted an Attestation in the past 12 months, you must do so immediately and annually thereafter.
NOTE: Your attestation must be signed/dated the year that it is due. For example, if you submit your attestation on June of 2016 and you submit your attestation for 2017 in December of 2016, the system will show two attestation for 2016 and none for 2017.
- Are we required to use CMS's and/or CHPW's GCFWA training material or can we use our own?
CMS has suspended (until further notice) the requirement that would have been effective January, 2016, that said providers must use General Compliance and FWA (GCFWA) Training courses available on the CMS MLN website.
Note: Your training courses must meet CMS standards and requirements should mirror the content on the MLN training course.
- Is there a link that will take me directly to the GCFWA training course on the MLN?
Yes, go to http://www.cms.gov/MLNProducts and scroll down to Downloads, and click on Medicare Part C and D Fraud, Waste, and Abuse and Medicare Parts Cand D General Compliance Training. Your inquires for the Medicare Learning Network (MLN), could be directed via e-mail at MLN@cms.hhs.gov.
- How to complete a General Compliance/FWA (GCFWA Attestation Form
The information on the attestation form is straightforward and simple. The form must be completed by entering information requested in all fields; handwriting must be legible and the form must be signed and dated. See below for instructions on how to submit the form to CHPW.
- How do I submit a completed General Compliance and FWA Attestation Form to CHPW?
Online Submission: https://portal.chpw.org/forms/provider#/gcfwa
Fax: 206-613-5018, ATTN: PROVIDER RELATIONS
E-mail: Send a scanned copy to GCFWA@chpw.org
USPS: Community Health Plan of Washington
C/O Provider Relations
1111 Third Ave, Ste. 400
Seattle, WA 98101
Should you have any additional questions or concerns, please contact your Provider Relations Representative
directly or send an email to Provider.Relations@CHPW.org. Please type GCFWA in the “subject” line.
- What should I do if I suspect fraud, waste, abuse, or other compliance issues?
There are a couple options for reporting suspected compliance issues. You can:
- Contact CHPW Customer Service at 1-800-440-1561/ CHPW Medicare Advantage Customer Service at 1-800-942-0247.
- Fill out a Report Potential Fraud form and submit it to the CHPW Compliance Department at firstname.lastname@example.org or by fax at 206-652-7017.
- Contact the appropriate state or federal agency to submit a report. You can contact CMS at 1-800-Medicare, the Washington State Healthcare Authority (HCA) at 1-800-562-6906, or the Office of the Inspector General at 1-800-HHS-TIPS
Should you have any additional question or concerns, please email us at GCFWA@CHPW.org. Include your clinic name and tax ID in the subject line.
Please note the following acronyms, terms, and definitions:
- CMS – Centers for Medicare and Medicaid Services
- HCA – Health Care Authority
- MA – Medicare Advantage
- CEO – Chief Executive Officer
- CHPW – Community Health Plan of WA
- FWA – Fraud, Waste and Abuse
- MLN – Medicare Learning Network
- GCFWA – General Compliance, Fraud, Waste and Abuse