Online Attestation

Network Provider Pharmacy Fraud, Waste and Abuse (FWA) and General Compliance Training; Terms and Conditions

Network Pharmacy Providers are required to sign electronically by submitting the online attestation below to satisfy mandatory compliance requirements related to guidance from the Centers for Medicare & Medicaid Services (CMS). CMS has set forth expressed guidance within the Federal Register at Title 42 of the Code of Federal Regulations (CFR), Parts 422/423 and other agency guidance requiring Medicare Advantage (MA), Medicare-Medicaid Plans (MMP) and Medicare Part D (PDP) sponsors ("Plan Sponsors") or First-tier, Down-stream and Related (FDR) entities to demonstrate compliance with the following:

1. Network Pharmacy Provider hereby attests to conducting the annual Fraud, Waste and Abuse (FWA) and General Compliance Training programs or has utilized the training program provided by CMS, including providing staff with links to our Plan Sponsor Code of Conduct policies located online at: In addition, Network Pharmacy Provider hereby attests to no exclusion from participation in federal health care programs by checking their status in the exclusion lists maintained by the Office of Inspector General (OIG) U.S. Department of Health & Human Services (HHS) and U.S. General Services Administration (GSA) System for Award Management (SAM). Network Pharmacy Provider has reviewed the OIG-HHS and GSA-SAM lists prior to hire/contracting and monthly thereafter for its current employees/contractors, health professionals or subcontracted delegates, working with Plan Sponsor programs to ensure none are excluded from participating in these programs.

Organizations contracted to administer federal and state health care programs are prohibited from hiring, continuing to employ, contract, make payments to persons/entities previously excluded/debarred from participation or procurement with federal and/or state health care programs.

You are required to review the OIG-HHS and GSA federal programs exclusion lists prior to hiring/contracting employees who are involved in the administration/delivery of Plan Sponsor benefits/services to ensure none of these persons/entities are excluded or become excluded from participation in federal programs. You are required to continue to monitor the federal exclusions lists on a monthly basis thereafter.

Please note: If you serve state health plans (e.g. UHC Community & State), you are also required to review state exclusion lists prior to hire and monthly thereafter, as referenced in the regulatory appendix of your vendor contract(s) or as modified by state requirements since contract execution.

These requirements are included in the following regulatory references:

  • Medicare - Medicare Managed Care Manual and Prescription Drug Benefit Manual Chapter 9/Chapter 21 - Section 50.6.8 at:

  • The Social Security Act §1862(e)(1)(B), 42 CFR §§ 422.503(b)(4)(vi)(F), 422.752(a)(8), 423.504(b)(4)(vi)(F), 423.752(a)(6), 1001.1901.

  • Medicaid - The authority for the requirement to review for exclusions is 42 CFR 1001.1901(b). The extension to state exclusion lists is under the authority of: 42 CFR 1002.2; applicable state law; and state Medicaid contracts, which control for all services performed for State health plans (e.g. UHC Community & State) in any given state, if applicable.

This information is available at the following sites:

Note :

  • As per June 17, 2015 CMS memo, beginning in 2016 only CMS training materials located on the Medicare Learning Network (MLN) will be allowed and the content of these materials cannot be modified in order to ensure the integrity and completeness of the training.
  • CMS does not require FDR entities to adopt Plan Sponsor Code of Conduct policies, but these sponsors distribute to FDR entities for the purposes of supporting CMS FWA and General Compliance requirements.

2. Network Pharmacy Provider hereby attests to maintaining attendance logs, materials, training documents and other evidence in support of compliance with item "1." above. Network Pharmacy Provider ensures supportive evidence is available to OptumRx or an auditor during on-site visits for inspection or other review processes. This inspection may also be conducted by the Payer(s) and other federal regulatory agencies as outlined in 42 CFR 422.504(e) and 422.503(d)(2).

3. Network Pharmacy Provider hereby attests to maintaining clearly defined processes to determine if your contracted vendors meet the definition of an FDR as per CMS requirements. Process documentation regarding auditing and monitoring of your FDR must be made available upon request.

Please ensure the following steps are implemented :

  1. Access the CMS Medicare Learning Network® (MLN) Provider Compliance site and download the zipped file containing the two attachments:
    • Click Here
      • Click on the zip file "Medicare Parts C and D Fraud, Waste, and Abuse Training and Medicare Parts C and D General Compliance Training" for the two attachments (i.e. "Medicare parts C & D Fraud, Waste, and Abuse Training and General Compliance Training" PDF and "CMS Medicare Parts C & D FWA Training and General Compliance Training" module).
  2. Distribute the training information (i.e. zipped file) to each of your pharmacy staff working with Medicare, Medicaid, Medicare-Medicaid and/or any other government business.
  3. CMS requires Network Pharmacy Providers to maintain records demonstrating compliance with these requirements for ten (10) years (i.e. training program completion/attendance logs in an easily accessible location).
    1. Download the OptumRx form below (or provide your own with required information stated below) for this purpose and keep it on file for future audit-purposes.
      • Do not send to OptumRx for storage-purposes.
    2. For audit-purposes, requested records require the information immediately by CMS, OptumRx or our Plan Sponsors.
      • In our experience, Auditors expect us to provide this information the same day of request and we greatly appreciate your cooperation.
    3. Include all individuals names and the date the FWA and general compliance training information is provided/completed, as well as the date of the Office of Inspector General's (OIG) U.S. Department of Health & Human Services (HHS)/General Services Administration (GSA) monitoring review.
      • CMS will accept an attestation confirming the organization has completed the appropriate compliance and FWA training. Attestations must include language specifying the entity complies with CMS compliance and FWA training requirements; the training provided includes CMS content without modification. In addition, it must include at least employee names, dates of employment, dates of completion, passing scores (if captured) to clearly document training completion.
    4. Click Here for the 2015 Medicare Fraud, Waste and Abuse (FWA) and General Compliance Training Log.

Network Pharmacy Agreement

* Indicates Required Field for Authorized Individual Completing Attestation

* Affiliation:
You should check with your PSAO, GPO or Chain before you complete this attestation. Your PSAO, GPO or Chain may attest on your behalf. Thank you.
*  Entity Name:
* First and Last Name:
* Title:
* Telephone Number: - -
NCPDP Number:
Chain Code:  

If you have more than one (1) NCPDP, please ensure all NCPDPs are listed before submitting your completed attestation.

Chain Code:            
    If you have more than one (1) chain code, please ensure that all chain codes are listed before submitting your completed attestation.

WAIVER: Please check box if this waiver applies to your organization. Ensure evidence be maintained in your files to provide for audit-purposes.

 Our organization has met the FWA certification requirements through enrollment into the Medicare program or accreditation as a Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS) provider. We are deemed to have met the training and education requirements for FWA per 423.504 (vi)(C) (3).

* By checking the "I agree" radio button below, you are attesting that your electronic signature states the above is accurate and complete. In addition, you agree to the terms and conditions of this attestation and are authorized to make such assertions on behalf of the above named Network Pharmacy Provider.

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