Why Do I Need Training? Fraud, Waste, And Abuse Training
9/16/2015Preferred IPAFraud, Waste, and Abuse TrainingGeneral Compliance TrainingHIPAA Compliance Training2015-2016This training program consists of three parts:1.Medicare Parts C & D Fraud, Waste, and Abuse (FWA)Training (Developed by the Centers for Medicare &Medicaid Services Issued: February, 2013)2.Medicare Parts C & D General Compliance Training(Developed by the Centers for Medicare & MedicaidServices Issued: February, 2013)3.Preferred IPA HIPAA Compliance TrainingAt the completion of your initial or annual training, sign theattestation at the end of the training packet.Providers may fax signed attestations to 818-265-0801Attention: FWA Compliance Attestation.Why Do I Need Training?Fraud, Waste,and AbuseTrainingEvery year millions of dollars are improperlyspent because of fraud, waste, and abuse. Itaffects everyone.Including YOU.This training will help you detect, correct, andprevent fraud, waste, and abuse.YOU are part of the solution.1
9/16/2015Objectives Meet the regulatory requirement for training andeducationProvide information on the scope of fraud, waste,and abuseExplain obligation of everyone to detect, prevent,and correct fraud, waste, and abuseProvide information on how to report fraud, waste,and abuseProvide information on laws pertaining to fraud,waste, and abuseWhere do I fit in? As a person who provides health oradministrative services to a Part C or Part D enrolleeyou are either: Part C or D Sponsor Employee First Tier Entity Examples: PBM, a Claims Processing Company, contractedSales Agent Downstream Entity Example: Pharmacy Related EntityRequirementsStatute, regulations, and policy govern the Medicare PartsA, B, C, and D programs.Part C and Part D contractors must have an effectivecompliance program which includes measures toprevent, detect and correct Medicare non-compliance aswell as measures to prevent, detect and correct fraud,waste, and abuse.In addition, contractors must have an effective training foremployees, managers and directors, as well as their firsttier, downstream, and related entities. (42 C.F.R.§422.503 and 42 C.F.R. §423.504)What are my responsibilities as an employee or a personwho provides health and administrative services in thePart C and Part D program? You are a vital part of the effort to prevent, detect, and reportMedicare non-compliance as well as possible fraud, waste, andabuse. FIRST you are required to comply with all applicable statutory,regulatory, and other Part C or Part D requirements, includingadopting and implementing an effective compliance program. SECOND you have a duty to the Medicare Program to report anyviolations of laws that you may be aware of. THIRD you have a duty to follow your organization’s Code ofConduct that articulates your and your organization’s commitment tostandards of conduct and ethical rules of behavior. Example: Entity that has a common ownership or control ofa Part C/D Sponsor2
9/16/2015An Effective Compliance Program Is essential to prevent, detect, and correctMedicare non-compliance as well as fraud,waste and abuse. Must, at a minimum, include the 7 corecompliance program requirements. (42 C.F.R.§422.503 and 42 C.F.R. §423.504)How do I Prevent Fraud,Waste, and Abuse? PreventionPolicies and Procedures Make sure you are up to date with laws, regulations,policies.Ensure you coordinate with other payers.Ensure data/billing is both accurate and timely.Verify information provided to you.Be on the lookout for suspicious activity. Every sponsor, first tier, downstream, andrelated entity must have policies andprocedures in place to address fraud, waste,and abuse. These procedures should assistyou in detecting, correcting, and preventingfraud, waste, and abuse.Make sure you are familiar with your entity’spolicies and procedures.3
9/16/2015What is Fraud, Waste, andAbuse?DetectionCriminal FRAUDKnowingly and willfully executing, or attempting toexecute, a scheme or artifice to defraud any healthcare benefit program; or to obtain, by means of falseor fraudulent pretenses, representations, orpromises, any of the money or property owned by,or under the custody or control of, any health carebenefit program.In order to detect fraud, waste, and abuseyou need to know the LawWhat Does That Mean?Intentionally submitting false information tothe government or a government contractorin order to get money or a benefit.18 United States Code §13474
9/16/2015Waste and AbuseWaste: overutilization of services or other practicesthat result in unnecessary costs to the MedicareProgram. Waste is not cause by criminally negligentactions but by the misuse of resources.Abuse: includes actions that result in unnecessary coststo the Medicare Program. Abuse involves paymentfor items or services when there is not legalentitlement and the provider has not knowingly andor/intentionally misrepresented facts to obtainpayment.Report Fraud, Waste,and AbuseDo not be concerned about whether it is fraud,waste, or abuse. Just report any concerns to yourcompliance department or your sponsor’scompliance department . Your sponsor’scompliance department area will investigate andmake the proper determination.Differences between Fraud,Waste, and AbuseThere are differences between fraud, waste, andabuse. One of the primary differences is intent andknowledge.Fraud requires the person to have an intent to obtainpayment and the knowledge that their actions arewrong. Waste and abuse may involve obtaining animproper payment, but does not require the sameintent and knowledge.Indicators of Potential Fraud,Waste, and AbuseNow that you know what fraud, waste, andabuse are, you need to be able to recognizethe signs of someone committing fraud,waste, or abuse.5
9/16/2015Indicators of Potential Fraud,Waste, and AbuseKey Indicators:Potential Beneficiary Issues The following slides present issues that may bepotential fraud, waste, or abuse. Each slide providesareas to keep an eye on, depending on your role as asponsor, pharmacy, or other entity involved in thePart C and/or Part D programs. Does the prescription look altered or possiblyforged?Have you filled numerous identical prescriptions forthis beneficiary, possibly from different doctors?Is the person receiving the service/picking up theprescription the actual beneficiary (identity theft)?Is the prescription appropriate based onbeneficiary’s other prescriptions?Does the beneficiary’s medical history support theservices being requested?Key Indicators:Key Indicators:Potential Provider IssuesPotential Provider IssuesDoes the provider write for diverse drugs orprimarily only for controlled substances?Are the provider’s prescriptions appropriate for themember’s health condition (medically necessary)?Is the provider writing for a higher quantity thanmedically necessary for the condition?Is the provider performing unnecessary services forthe member? Is the provider’s diagnosis for themember supported in the medicalrecord?Does the provider bill the sponsor forservices not provided?6
9/16/2015 Key Indicators:Key Indicators:Potential Pharmacy IssuesPotential Pharmacy IssuesAre the dispensed drugs expired, fake, diluted, orillegal?Do you see prescriptions being altered (changingquantities or Dispense As Written)?Are proper provisions made if the entire prescriptioncannot be filled (no additional dispensing fees forsplit prescriptions)?Are generics provided when the prescriptionrequires that brand be dispensed? Are PBMs being billed for prescriptions thatare not filled or picked up?Are drugs being diverted (drugs meant fornursing homes, hospice, etc. being sentelsewhere)?Key Indicators:Key Indicators:Potential Wholesaler IssuesPotential Manufacturer IssuesIs the wholesaler distributing fake, diluted, expired,or illegally imported drugs?Is the wholesaler diverting drugs meant for nursinghomes, hospices, and AIDS clinics and thenmarking up the prices and sending to other smallerwholesalers or to pharmacies? Does the manufacturer promote off labeldrug usage?Does the manufacturer provide samples,knowing that the samples will be billedto a federal health care program?7
9/16/2015Key Indicators:Potential Sponsor Issues Does the sponsor offer cash inducements forbeneficiaries to join the plan?Does the sponsor lead the beneficiary to believe thatthe cost of benefits are one price, only for thebeneficiary to find out that the actual costs arehigher?Does the sponsor use unlicensed agents?Does the sponsor encourage/support inappropriaterisk adjustment submissions?Reporting Fraud, Waste, andAbuseEveryone is required to report suspectedinstances of fraud, waste, and abuse. Yoursponsor’s Code of Conduct and Ethics shouldclearly state this obligation. Sponsors maynot retaliate against you for making a goodfaith effort in reporting.How do I report Fraud,Waste, or Abuse?Reporting Fraud, Waste, andAbuseEvery MA-PD and PDP sponsor is required to have amechanism in place in which potential fraud, waste, or abusemay be reported by employees, first tier, downstream, andrelated entities. Each sponsor must be able to acceptanonymous reports and cannot retaliate against you forreporting. Review your sponsor’s materials for the ways toreport fraud, waste, and abuse.When in doubt, call the MA-PD or PDP fraud, waste, andabuse Hotline or the Compliance Department.8
9/16/2015SuspectedFraud,Fraud, Waste,Abuseor othernoncompliancemay be maySuspectedWaste,&&Abuseor othernoncompliancereported by calling:bereportedbycontacting: Medi-Cal (800) 822-6222 Medicare (800) 447-8477Anthem(877)725-2702Medi-Cal (800) 822-6222or stopmedicalfraud@dhcs.ca.govCare 1st(877)837-6057Medicare(800)447-8477or (800) HHS-TIPSEasy Choice 9HealthNet (800) 977-3565Care 1st(877) 837-6057Humana(800) 614-4126Citizen’sChoice(562) 207-4575Molina(866) 449-6850EasyChoice(866)678-8355Preferred IPA(800) 536-2867LA CareHealth NetHumanaMolinaPreferred IPACorrection(800) 400-4889(800) 977-3565(800) 614-4126(866) 606-3889(800) 536-2867 or (818)844-8060CorrectionOnce fraud, waste, or abuse has been detectedit must be promptly corrected. Correcting theproblem saves the government money andensures you are in compliance with CMS’requirements.How Do I Correct Issues?Once issues have been identified, a plan to correctthe issue needs to be developed. Consult yourcompliance officer or your sponsor’s complianceofficer to find out the process for the correctiveaction plan development.The actual plan is going to vary, depending on thespecific circumstances.9
9/16/2015LawsLaws You Needto Know AboutCivil FraudCivil False Claims ActThe following slides provide very high levelinformation about specific laws. For detailsabout the specific laws, such as safe harborprovisions, consult the applicable statute andregulations concerning the law.Civil False Claims ActDamages and PenaltiesProhibits: Presenting a false claim for payment or approval;Making or using a false record or statement in support of a false claim;Conspiring to violate the False Claims Act;Falsely certifying the type/amount of property to be used by theGovernment;Certifying receipt of property without knowing if it’s true;Buying property from an unauthorized Government officer; andKnowingly concealing or knowingly and improperly avoiding ordecreasing an obligation to pay the Government.The damages may be tripled. Civil MoneyPenalty between 5,000 and 10,000 for eachclaim.31 United States Code § 3729-373310
9/16/2015Criminal Fraud PenaltiesAnti-Kickback StatuteProhibits:If convicted, the individual shall be fined,imprisoned, or both. If the violations resultedin death, the individual may be imprisonedfor any term of years or for life, or both.Knowingly and willfully soliciting, receiving, offeringor paying remuneration (including any kickback,bribe, or rebate) for referrals for services that arepaid in whole or in part under a federal health careprogram (which includes the Medicare program).18 United States Code §134742 United States Code §1320a-7b(b)Anti-Kickback StatutePenaltiesFine of up to 25,000, imprisonmentup to five (5) years, or both fine andimprisonment.Stark Statute(Physician Self Referral Law)Prohibits a physician from making a referral forcertain designated health services to an entity inwhich the physician (or a member of his or herfamily) has an ownership/investment interest orwith which he or she has a compensationarrangement (exceptions apply).42 United States Code §1395nn11
9/16/2015Stark Statute Damages andPenaltiesMedicare claims tainted by an arrangementthat does not comply with Stark are notpayable. Up to a 15,000 fine for eachservice provided. Up to a 100,000 finefor entering into an arrangement orscheme.ExclusionNo Federal health care program payment maybe made for any item or service furnished,ordered, or prescribed by an individual orentity excluded by the Office of InspectorGeneral.42 U.S.C. §1395(e)(1)42 C.F.R. §1001.1901HIPAAHealth Insurance Portability and Accountability Act of1996 (P.L. 104-191)Created greater access to health care insurance, protection of privacy ofhealth care data, and promoted standardization and efficiency in thehealth care industry.ConsequencesSafeguards to prevent unauthorized access to protected health careinformation.As a individual who has access to protected health care information, you areresponsible for adhering to HIPAA.12
9/16/2015Consequences of CommittingFraud, Waste, or Abuse The following are potential penalties. Theactual consequence depends on the violation. Civil Money Penalties CriminalConviction/Fines Civil Prosecution Imprisonment Loss of Provider License Exclusion from Federal Health Care programsScenario # 1A.B.C.D.E.Fill the prescription for 160Fill the prescription for 60Call the prescriber to verify quantityCall the sponsor’s compliancedepartmentCall law enforcementScenario # 1A person comes to your pharmacy to drop offa prescription for a beneficiary who is a“regular” customer. The prescription is for acontrolled substance with a quantity of 160.This beneficiary normally receives a quantityof 60, not 160. You review the prescriptionand have concerns about possible forgery.What is your next step?Scenario # 1 AnswerAnswer: CCall the prescriber to verifyIf the subscriber verifies that the quantityshould be 60 and not 160 your next stepshould be to immediately call the sponsor’scompliance hotline. The sponsor will providenext steps.13
9/16/2015Scenario # 2Your job is to submit risk diagnosis to CMS forpurposes of payment. As part of this job youare to verify, through a certain process, thatthe data is accurate. Your immediatesupervisor tells you to ignore the sponsor’sprocess and to adjust/add risk diagnosis codesfor certain individuals.Scenario # 2A.B.C.D.Do what is asked of your immediatesupervisorReport the incident to the compliancedepartment (via compliance hotline or othermechanism)Discuss concerns with immediate supervisorContact law enforcementWhat do you do?Scenario # 2 AnswerAnswer: BReport the incident to the compliance department(via compliance hotline or other mechanism)The compliance department is responsible forinvestigating and taking appropriate action. Yoursponsor/supervisor may NOT intimidate or takeretaliatory action against you for good faithreporting concerning a potential compliance, fraud,waste, or abuse issue.Scenario # 3You are in charge of payment of claims submittedfrom providers. You notice a certain diagnosticprovider (“Doe Diagnostics”) has requested asubstantial payment for a large number of members.Many of these claims are for a certain procedure. Youreview the same type of procedure for other diagnosticproviders and realize that Doe Diagnostics’ claims farexceed any other provider that you reviewed.What do you do?14
9/16/2015Scenario # 3A.B.C.D.E.Call Doe Diagnostics and request additionalinformation for the claimsConsult with your immediate supervisor fornext stepsContact the compliance departmentReject the claimsPay the claimsScenario # 3 AnswerAnswers B or CConsult with your immediate supervisor for next stepsorContact the compliance departmentEither of these answers would be acceptable. Youdo not want to contact the provider. This mayjeopardize an investigation. Nor do you want topay or reject the claims until further discussionswith your supervisor or the compliance departmenthave occurred, including whether additionaldocumentation is necessary.Scenario # 4Scenario # 4A.You are performing a regular inventory of thecontrolled substances in the pharmacy. Youdiscover a minor inventory discrepancy. Whatshould you do?B.C.D.E.Call the local law enforcementPerform another reviewContact your compliance departmentDiscuss your concerns with your supervisorFollow your pharmacies procedures15
9/16/2015Scenario # 4 AnswerAnswer EFollow your pharmacies proceduresSince this is a minor discrepancy in theinventory you are not required to notify theDEA. You should follow your pharmaciesprocedures to determine the next steps.ComplianceTrainingCongratulations! You haveCompleted the Centers forMedicare & Medicaid Services’Part C and Part D Fraud,Waste, and Abuse Training Compliance is EVERYONE’Sresponsibility!As an individual who provides health oradministrative services for Medicareenrollees, every action you takepotentially affects Medicare enrollees,the Medicare program, or the Medicaretrust fund.16
9/16/2015 Understand the organizationscommitment to ethical business behaviorUnderstand how a compliance programoperatesGain awareness of how complianceviolations should be reportedA culture of compliance within an organization: Prevents noncompliance Detects noncompliance Corrects noncompliance CMS requires Medicare Advantage, MedicareAdvantage-Prescription Drug, and PrescriptionDrug Plan Sponsors (“Sponsors”) to implement aneffective compliance program.An effective compliance program should:Provide guidance on how to handle compliance questionsand concerns Provide guidance on how to identify and reportcompliance violations Articulate and demonstrate an organization’s commitmentto legal and ethical conduct At a minimum, a compliance program must include the 7 core requirements:1. Written Policies, Procedures and Standards of Conduct;2. Compliance Officer, Compliance Committee and High LevelOversight;3. Effective Training and Education;4. Effective Lines of Communication;5. Well Publicized Disciplinary Standards;6. Effective System for Routine Monitoring and Identification ofCompliance Risks; and7. Procedures and System for Prompt Response to Compliance Issues42 C.F.R. §§ 422.503(b)(4)(vi) and 423.504(b)(4)(vi); Internet-Only Manual (“IOM”), Pub. 100-16, MedicareManagedCare Manual Chapter 21; IOM, Pub. 100-18, Medicare Prescription Drug Benefit Manual Chapter 917
9/16/2015 CMS expects that all Sponsors will applytheir training requirements and “effectivelines of communication” to the entities withwhich they partner. Having “effective lines of communication”means that employees of the organization andthe partnering entities have several avenuesthrough which to report compliance concerns.As a part of the Medicare program, it isimportant that you conduct yourself in anethical and legal manner. It’s about doing the right thing! Act Fairly and Honestly Comply with the letter and spirit of the law Adhere to high ethical standards in all thatyou do Report suspected violations Standards of Conduct (or Code of Conduct) statecompliance expectations and the principles andvalues by which an organization operates.Contents will vary as Standards of Conduct shouldbe tailored to each individual organization’s cultureand business operations.Everyone is required to report violations ofStandards of Conduct and suspected noncompliance.An organization’s Standards of Conduct andPolicies and Procedures should identify thisobligation and tell you how to report. Noncompliance is conduct that does not conform tothe law, and Federal health care programrequirements, or to an organization’s ethical andbusiness policies.High Risk Areas: CredentialingEthicsHIPAAClaims, Appeals & GrievancesMarketing and Enrollment, Marketing & EnrollmentAgent and brokerConflict of Interest18
9/16/2015Without programs to prevent, detect,and correct noncompliance thereare: Delayed Services Denied of benefits Difficulty using providers of choice Hurdles to care There can be NO retaliation against you forreporting suspected noncompliance in goodfaith. Non Compliance affects EVERYBODY! Without programs to prevent, detect, andcorrect noncompliance you risk: Higherpremiumsprofits Higher insurance copayments Lower benefits for individuals and employers Lower star ratings Lower Suspected Fraud, Waste, & Abuse or other noncompliancemay be reported by calling: Medi-Cal (800) 822-6222 or stopmedicalfraud@dhcs.ca.govMedicare(800) 447-8477 or (800) HHS-TIPSAnthem(877) 725-2702Care 1st(877) 837-6057Citizen’s Choice (562) 207-4575Easy Choice(866) 678-8355LA Care(800) 400-4889Health Net(800) 977-3565Humana(800) 614-4126Molina(866) 606-3889Preferred IPA(800) 536-2867 or (818)844-8060 Each Sponsor must offer reporting methodsthat are: Confidential Anonymous Non-retaliatory 19
9/16/2015After noncompliance has been detected It must be investigated immediately and thenpromptly correct any noncompliance Correcting Noncompliance Avoids the recurrence of the same noncompliancePromotes efficiency and effective internal controlsProtects enrolleesEnsures ongoing compliance with CMS requirementsYour organization is required to havedisciplinary standards in place for noncompliant behavior. Those who engage innon-Compliant behavior may be subject toany of the following: Mandatory Training or Disciplinary Action TerminationRetraining Once noncompliance is detected and corrected, anongoing evaluation process is critical to ensure thenoncompliance does not recur. Monitoring activities are regular reviews whichconfirm ongoing compliance and ensure thatcorrective actions are undertaken and effective. Auditing is a formal review of compliance with aparticular set of standards (e.g., policies andprocedures, laws and regulations) used as basemeasures PREVENT DETECT & REPORT Operate within your organization’s ethical expectations toPREVENT noncompliance!If you DETECT potential noncompliance, report itCORRECT CORRECT noncompliance to protect beneficiaries and tosave money!20
9/16/2015 Social Security Act: Title 18 Code of Federal Regulations*: 42 CFR Parts 422 (Part C) and 423 (Part D) CMS Guidance: Manuals HPMS Memos CMS Contracts: Private entities apply and contracts are renewed/non-renewed each year Other Sources: OIG/DOJ (fraud, waste and abuse (FWA)) HHS (HIPAA privacy) State Laws: Licensure Financial Solvency Sales Agents* 42 C.F.R. §§ 422.503(b)(4)(vi) and 423.504(b)(4)(vi)Congratulations! You haveCompleted the Centers forMedicare & MedicaidServices’ ComplianceTraining For more information on laws governing the Medicare program andMedicare noncompliance, or for additional healthcare complianceresources please see: Title XVIII of the Social Security Act Medicare Regulations governing Parts C and D (42 C.F.R. §§ 422 and423) Civil False Claims Act (31 U.S.C. §§ 3729-3733) Criminal False Claims Statute (18 U.S.C. §§ 287,1001) Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)) Stark Statute (Physician Self-Referral Law) (42 U.S.C. § 1395nn) Exclusion entities instruction (42 U.S.C. § 1395w-27(g)(1)(G)) The Health Insurance Portability and Accountability Act of 1996(HIPAA) (Public Law 104-191) (45 CFR Part 160 and Part 164, SubpartsA and E) OIG Compliance Program Guidance for the Healthcare guidance/index.aspHIPAAOverview of Privacy, Security andHITECHStaff Training21
9/16/2015PHIWho is Affected by HIPAA? Medical practicesHospitalsAmbulatory surgery centersHealthcare plansFiscal intermediariesBusiness officesVendorsClearinghousesBusiness Associates1. Name2. Any address specification such as street, city,county, precinct, and zip code3. All dates except for the year including birthdate,admission date, discharge date, date of death and allages over 894. Telephone number5. Fax number6. Electronic mail address PROTECTED HEALTH INFORMATIONMust be protected from disclosure: At the office In the field On the phone Verbal DocumentsIdentifiable Information(cont ) 7. Social Security number8. Medical record number9. Health plan beneficiary number10.Account number maintained by thehealthcare provider11.Certificate or license number such asdriver’s license number12.Vehicle identifier and serial numberincluding license plate number22
9/16/2015Identifiable Information(cont.) Physical Safeguards 13. Medical device identifier and serial numbersuch as pacemaker serial number14. Web site addresses15. Internet protocol (IP) address number16. Biometric identifier including finger andvoice prints17. Full face photographic images and anycomparable image, and18. Any other unique identifying number,characteristic or codeFacility Access ControlsWorkstation Use Workstation Security Device & Media Controls Documents transported to and from meetings inthe field Willful Neglect Conscious, intentional failure or recklessindifference to the obligation to complywith the administrative simplificationprovision violated.Relate to policies and procedures ensuring thesecurity of the physical practice to authorizedaccess.Criminal Penalties “Knowingly obtain and disclose PHI”23
9/16/2015Penalties Criminal penalties up to 100,000Actual DamagesPunitive damagesAttorney feesCosts of investigation The California Medical Information Act(CMIA) limits the access, use or disclosure ofan individual's medical information. 56.10(a) No provider of health care, health careservice plan, or contractor shall disclosemedical information regarding apatient without first obtaining anauthorization, except as provided in subdivision(b) or (c) and as allowed or specified underHIPAABreach PIPA has to report breaches ofunsecured PHI to covered entity then thecovered entity may have to notify theSecretary of DHHS.Liability for CompensatoryDamages Any individual may bring action against any person or entity who has negligently released information or records concerning him or her for nominal damages up to 1000 and/or the amount of actual damages sustained. Any violation that results in economic loss or personal injury to a patient may incur liability for compensatory damages of up to 3000, attorney’s fees up to 1000, and the costs of litigation.24
9/16/2015EMAIL SUBJECT LINE If the contents (and/or subject line) ofe-mails you send contain unsecured"Protected Health Information" (PHI), itis in violation of the Health InsurancePortability and Accountability Act(HIPAA) of 1996 regarding disclosureof personally identifiable healthinformation. IMPORTANT REMINDERS:Emails outside your internal email system are notsecure. Do not include member information.Obtain enough information from callers to confirmthat they are who they state they are before givingout information.Do not give out PHI of adult members to family,friends, or others without consent of the patient.When in doubt ask a manager.WHAT TO DO IF EMAIL IS RECEIVEDWITHOUT ENCRYPTION Immediately notify the sender that you have received anemail that is not “secure” or “encrypted” format so that theycan address the compliance issueThis text is available to all staff to copy and paste intoresponse email:Thank you for the email, this email containing ProtectedHealth Information (PHI) was sent without a secure orencrypted format. I wanted to let you know so that youwould be aware of the issue and notify your IT department ifthe encrypted email function failed. It is our policy to notifythe sender in these instances, we appreciate your cooperationwith our HIPAA policies and procedures.Congratulations! You haveCompleted the PreferredIPA HIPAA ComplianceTraining25
FWA, COMPLIANCE & HIPAA TRAINING INDIVIDUAL ATTESTATIONI have completed the Preferred IPA of California Annual Fraud, Waste and Abuse training.I have completed the Preferred IPA of California Annual Compliance training.I have completed the Preferred IPA of California Annual HIPAA training.¾¾I understand that I am responsible for reporting possible HIPAA, Compliance and/or Fraud,Waste and Abuse violations that may come to my attention.I further understand that when transporting documents that contain HIPAA protected healthinformation, I will do so in a sealed container such as an envelope, folder, zipped bag or othermethod of transport to secure the documents. I will immediately report to my supervisor theloss of any documents containing protected health information.IPA/Medical Group Name: Preferred IPA of CaliforniaDate: Print Name:Signature:Office Name:Phone:Fax to 818-265-0801 Attention: FWA Attestation
9/16/2015 1 Preferred IPA Fraud, Waste, and Abuse Training General Compliance Training HIPAA Compliance Training 2015-2016 This training program consists of three parts: 1. Medicare Parts C & D Fraud, Waste, and Abuse (FWA) Training (Developed by the Centers for Medicare & Medicaid Services Issued: February, 2013) 2.File Size: 668KB
Texts of Wow Rosh Hashana II 5780 - Congregation Shearith Israel, Atlanta Georgia Wow ׳ג ׳א:׳א תישארב (א) ׃ץרֶָֽאָּהָּ תאֵֵ֥וְּ םִימִַׁ֖שַָּה תאֵֵ֥ םיקִִ֑לֹאֱ ארָָּ֣ Îָּ תישִִׁ֖ארֵ Îְּ(ב) חַורְָּ֣ו ם
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The need for training might occur due to various reasons such as differences in values or culture (Sargent & Stupak, 1989). Rossett (1995) defined training need as a gap between current state of performance and desired state of performance, mapped after training need analysis. Few authors defined training need as gap between the
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