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Fraud, Waste and Abuse Training and Attestation

The Social Security Act and CMS regulations and guidance that govern the Medicare program requires that Medicare Part D Plan Sponsors must establish, implement and provide effective compliance and fraud, waste and abuse (FWA) training for employees, managers and directors, as well as their first tier, downstream, and related entities. (42 C.F.R. §422.503 and 42 C.F.R. §423.504). As a downstream entity of Navitus Health Solutions, a first-tier entity to Medicare Part D Plan Sponsors, participating pharmacies are required to provide compliance and FWA training to all employees within 90 days of initial hiring and annually thereafter. This requirement may be satisfied through classroom training or online training modules. Participating pharmacies may elect to use their own training materials, or utilize the CMS Medicare Learning Network (MLN) compliance and FWA training modules at https://learner.mlnlms.com/Default.aspx. Participating pharmacies must also maintain copies of sign-in sheets, electronic certifications or attestations from all employees who have completed the training, as well as copies of any materials used for training if the pharmacy utilizes their own materials. Participating pharmacies must also maintain and make available upon request proof of such training. Pharmacies participating in the Navitus pharmacy network must complete the online attestation included in the link below annually as documentation that they are in compliance with CMS compliance and FWA training requirements. Instructions on how to register and access training can be found here.

 

Please complete the online attestation form located here to indicate you have completed the FWA Compliance Training.

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