The Centers for Medicare & Medicaid Services (CMS) has modified certain rules and regulations of the Medicare Advantage program which became effective on January 1, 2009.  These rules necessitated certain changes to the contracts between providers and Medicare Advantage (MA) Organizations like Unison. The rule (which was published at 72 FR 68700 – 68741) updated the compliance plan requirements for Unison.  Specifically, the regulation states that a compliance plan, which must include measures to detect, correct, and prevent fraud, waste, and abuse, must also consist of training, education, and effective lines of communication between the compliance officer and the organization’s employees, managers, directors, as well as first tier, downstream and related entities. This change clarified that plan sponsors like Unison need to apply these training and communication requirements to all entities they are partnering with in the MA and Part D programs, not just direct employees. Your organization is a first tier or downstream entity.

Unison is responsible for ensuring that your organization is provided with appropriate training. Unison is providing your organization with training materials in the form of the PowerPoint presentation. Click here to access the document.  Your organization should administer the training materials. Your organization should maintain records of the training (i.e. sign in sheets, materials, etc). The training must be provided annually, and needs to be completed for the first time BEFORE January 1, 2010.