AOA answers common questions about Medicare Advantage fraud, waste and abuse training

AOA answers common questions about Medicare Advantage fraud, waste and abuse training

Most optometrists who contract with Medicare Advantage (MA) plans won't have to undergo fraud, waste and abuse training.

The AOA clarifies this point and others in a new "frequently asked questions" (FAQ) document that addresses a final rule the Centers for Medicare and Medicaid Services issued in 2007. Although it was issued seven years ago and updated in 2010, the AOA continues to receive questions about this requirement.

The FAQ, available to AOA members, seeks to assist ODs in better understanding how the requirements in this rulemaking affect their practices.

The final rule called on MA plans to put compliance plans into place to detect, correct and prevent fraud, waste and abuse (FWA). Plans had to require FWA training of a number of different entities, including "first tier, downstream, and related entities," such as a company contracted to provide claims processing or marketing services.

"Since MA plans contract with physicians, a literal reading of the regulations suggested that Medicare Advantage plans could only be in compliance if they had all of their contracted physicians complete the training," the AOA's FAQ explains.

Most ODs won't have to complete training
ODs who contract with MA plans likely fall into the category of "first tier or downstream entity." But as the FAQ explains, physicians enrolled in Medicare are exempt from the 2007 rule's training requirements.

In 2010, the agency clarified that any first tier, downstream or related entities that had already met FWA certification requirements by enrolling in Medicare didn't need further training and education. The agency had responded to concerns by AOA and other health care practitioner organizations that doctors were already well aware of their obligations to avoid FWA, and that annual training wasn't needed for those who had been screened through Medicare's enrollment process.

Had they not been exempt, they would have had to complete this training on an annual basis.

The exemption doesn't apply to everyone. ODs who contract with MA plans—but are not enrolled in Medicare—might still be required by the MA plan to complete the annual training to ensure it remains in compliance with CMS regulations.

In response to another frequently asked question, the FAQ says that AOA does not have a specific training program available for FWA. CMS has developed a compliance program that is available at no charge.

September 3, 2014

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