Banner Health Plans (BHP) General Compliance and Fraud, Waste, and Abuse (FWA) training is now available on our website. First Tier, Downstream and Related
Entities (FDR) can take our training or a comparable training. FDRs are required to complete an attestation and submit it to BHP indicating that the employees involved in the administration of Medicare Part C and D benefits have satisfied the training requirement. For FDRs (Subcontractors) under the Medicaid line of business, the following are required training elements:
a. Detailed information about the Federal False Claims Act
b. The administrative remedies for false claims and statements
c. Any State laws relating to civil or criminal liability or penalties for false claims and statements
d. The whistleblower protections under such laws
Documentation of internal training can be through an individual certificate or a list showing the information for all of those who completed it through the internal web-based training.
The Compliance Departments or Vendor Oversight Staff track completion of training by FDRs through the completion and collection of annual attestations from all FDRs.
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