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Compliance/Fraud, Waste & Abuse

Who needs to have a compliance program and FWA training?

Any provider or organization that contracts with Select Health to participate in the Select Health Medicare or pharmacy network is considered a “first-tier, downstream, and related entity” (FDR) under the Centers for Medicare & Medicaid Services (CMS) guidelines.

View FDR definitions.

As well as FDRs, Select Health providers and employees who perform services related to the Select Health

Medicare product or to plan enrollees must comply with program, training, and attestation requirements.

What are the government-mandated requirements?

Per the Centers for Medicare and Medicaid Services (CMS) Medicare Managed Care Manual Ch. 21 (50.3.2), practitioners who work for an organization accepting funding from Medicare or any government agency are required to complete these three steps:

Maintain a compliance program that includes elements outlined in the table below.

Participate in FWA training covering your in-place compliance/FWA program; records of this training may be reviewed by CMS during compliance audit proceedings. Complete the online attestation form to validate completion of compliant training. as required .

Implement or adhere to a compliance program including:

  • Adopting policies and procedures to prevent Fraud, Waste, and Abuse (FWA), promote ethical conduct, and ensure compliance with Federal and State laws, regulations, and other requirements relating to the Medicare program
  • Distributing your organization's code of conduct annually. If your organization does not have its own code of conduct, share the Intermountain Health/Select Health Code of Conduct with your employees.
  • Performing exclusion screening (via the Department of Health and Human Services Office of Inspector General [OIG] List of Excluded Entities and Individuals [LEIE], and the General Services Administration System for Award Management [GSA/SAM]
  • Maintaining a program for FWA reporting and communication channels.
  • Auditing and monitoring any contracted vendors that perform Medicare functions.
  • Ensuring 10-year records retention (e.g., sign-in sheets, employee attestations, and electronic certifications from those taking and completing the training.) Select Health or CMS may request this documentation as part of a compliance audit.

Train employees and contractors supporting Select Health Medicare plans on compliance policies and FWA, although use of the CMS material is not required.

Note that:

  • You should administer training within 90 days of contract/hire and annually thereafter as a best practice.
  • The content of the training is at the discretion of your organization. The use of previous, CMS-issued content is no longer mandatary, but is an available option. Access that training.
  • If the FDR does not have their own training, they may request a copy from Select Health.

See Combating Medicare Parts C & D Fraud, Waste, & Abuse for more detail.

How do we report potential FWA?

Call the Compliance Hotline at 800-442-4845. Anonymous reporting and interpretation services are available.

Where can we learn more?

To speak to someone or ask questions about plan benefits or coverage, call Member Services at 800-538-5038 (TTY: 711). Learn more by:

Questions? Contact your local Provider Relations representative at: