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Medicare Compliance Expectations and Training - Chapter 16, 2018 UnitedHealthcare Administrative Guide

CMS requires Medicare Advantage (MA) Organizations and Part D Plan Sponsors, including UnitedHealthcare, to annually communicate specific Compliance and FWA requirements to their “first tier, downstream, and related entities” (FDRs). FDRs include contracted physicians, health care professionals, facilities and ancillary providers, as well as delegates, contractors, and related parties. The employees of FDRs working on MA and Part D programs, including contracted care providers, must complete the two requirements below within 90 days of employment and annually thereafter (by the end of the year). This includes temporary workers and volunteers, the CEO, senior administrators or managers, and sub delegates who are involved in or responsible for the administration or delivery of UnitedHealthcare MA or Part D benefits or services. The required education, training, and screening requirements include the following:

Standards of Conduct Awareness

Provide a copy of your own code of conduct, or the UnitedHealth Group’s (UHG’s) Code of Conduct (at > About > Ethics & Integrity > UnitedHealth Group’s Code of Conduct).

What You Need to Do
Provide your own or the UHG’s Code of Conduct as outlined in the Standards of Conduct Awareness Section included herein and maintain records of distribution standards (i.e. in an email, website portal or contract) for 10 years. We, or CMS, may request documentation to verify compliance.

Fraud, Waste, and Abuse and General Compliance Training

Provide FWA and General Compliance training to employees and contractors of the FDR working on MA and Part D programs.

As of Jan. 1, 2016, CMS requires the use of CMS published training materials to meet compliance training requirements. You have met CMS FWA training and education requirements if you complete FWA certification through a fee-for-service Medicare program, or through accreditation as a supplier of Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS); however, FDRs must still complete the General Compliance Training available on the CMS Medicare Learning Network® at

You cannot alter the published CMS training material content, but you can download CMS training material and add information specific to your organization.

What You Need to Do

  • Administer FWA and General Compliance training. You can access the materials available on the CMS Medicare Learning Network® at:
  • Maintain a record of completion (i.e., method, training materials, dated employee sign-in sheet(s), attestations or electronic certifications that include the date of the training) for 10 years. We, or CMS, may request documentation from you to verify compliance with this requirement.