Nivano Physicians, Inc.
Effective Date: March 12, 2026
Last Updated: March 12, 2026
Version: 2.0
Purpose
The Centers for Medicare & Medicaid Services (CMS) require Medicare Advantage Organizations (MAOs) to ensure that all network providers, practitioners, and First-tier, Downstream, and Related Entities (FDRs) complete annual compliance and Fraud, Waste, and Abuse (FWA) training. This page describes those requirements, who they apply to, how to complete them, and how to document completion for Nivano Physicians’ records.
Regulatory Framework
This training program is established in accordance with:
- 42 C.F.R. § 422.503(b)(4)(vi) — Medicare Advantage compliance program requirements for FDR training
- 42 C.F.R. § 423.504(b)(4)(vi) — Part D compliance program requirements for FDR training
- Medicare Managed Care Manual, Chapter 21 — Compliance Program Guidelines
- Prescription Drug Benefit Manual, Chapter 9 — Part D Compliance Requirements
- CMS Compliance Training, Education & Outreach (CTEO) standards
- OIG General Compliance Program Guidance for Healthcare Organizations
Provider and FDR Training Requirements
This section applies to all Nivano Physicians network providers, practitioners, contracted administrators, and any organization that qualifies as a First-tier, Downstream, or Related Entity (FDR) under CMS definitions.
Who Must Complete Training
CMS defines FDRs as any entity that has a written agreement with a MAO to provide administrative or health care services on behalf of the plan. This includes:
- Contracted physicians and physician groups
- Specialist providers within the Nivano network
- Delegated entities performing utilization management, credentialing, or claims functions
- Contracted administrative vendors with access to Medicare beneficiary data
Required Training Modules
Effective January 1, 2021, all FDRs must complete the following training through the Medicare Learning Network (MLN):
| Module | Required For | Notes |
|---|---|---|
| General Compliance Training | All FDRs — no exemptions | Required annually |
| Fraud, Waste, and Abuse (FWA) Training | All FDRs — unless exempt (see below) | Required annually |
Both modules are available at no cost at:
https://www.cms.gov/training-education/medicare-learning-network-mln
Completion Deadlines
| Circumstance | Deadline |
|---|---|
| New FDR — initial training | Within 90 days of contracting or becoming a delegated entity |
| All FDRs — annual refresher | By December 31 of each calendar year |
Group Attestation
One designated individual may attest to training completion on behalf of an entire organization, provided that every individual within the organization has independently completed all required modules. The attestation represents that each person completed the training — it does not substitute for individual completion.
FWA Training Exemptions
FDRs are exempt from the FWA training module only if they meet one of the following criteria:
- Currently enrolled in Medicare Part A or certified to provide Part B services
- Accredited as a Supplier of DMEPOS (Durable Medical Equipment, Prosthetics, Orthotics, and Supplies)
Important: The FWA training exemption does not extend to General Compliance training. General Compliance training remains mandatory for all FDRs regardless of exemption status.
Submitting Completion Documentation to Nivano Physicians
After completing required training, providers and FDRs must submit documentation of completion to:
Compliance Department — Nivano Physicians, Inc.
Email: compliance@nivanophysicians.com
Phone: (916) 407-2000
Toll Free: (844) 889-2273
Mail: Attn: Compliance, PO Box 869140, Plano, TX 75086
Documentation should include the individual’s name, organization, training module completed, and date of completion. MLN certificates of completion are acceptable.
For questions about FDR training requirements, contact Provider Services at (844) 889-2273, Monday through Friday, 8:00 a.m. to 5:00 p.m. PST.
Internal Staff Training Program
The following applies to Nivano Physicians employees and internal staff.
Required Training by Role
| Training Type | Audience | Completion Window |
|---|---|---|
| General Compliance | All staff | Within 30 days of hire; annually by December 31 |
| Fraud, Waste, and Abuse | All staff | Within 30 days of hire; annually by December 31 |
| HIPAA Privacy and Security | All staff with PHI access | Within 30 days of hire; annually |
| Part C (Medicare Advantage) | Member-facing and administrative staff | Upon role assignment; annually |
| Part D (Prescription Drug Plan) | Applicable staff | Upon role assignment; annually |
| Role-specific compliance | As required by position | As assigned |
| Remedial training | Staff with compliance gaps | Within timeframe specified by Compliance Officer |
Part C Training Content
Internal Part C compliance training covers:
- Organization determinations, coverage decisions, and medical necessity
- Appeals and grievances — processing procedures and member rights
- Marketing and sales — CMS-approved materials and enrollment practices
- Enrollment and disenrollment — procedures and documentation
- Quality assurance — Stars ratings and quality improvement programs
- Network management — provider credentialing and oversight
- Fraud, waste, and abuse — detection and prevention
Part D Training Content
Internal Part D compliance training covers:
- Coverage determinations, formulary management, and exceptions
- Appeals and grievances — multi-level processes
- Prescription Drug Event (PDE) data submission requirements
- Low-Income Subsidy (LIS) eligibility and processing
- Medication Therapy Management (MTM) program requirements
- Pharmacy network management and contract compliance
- Part D CMS reporting obligations
- Prescription drug FWA issues
Training Resources
Official CMS and Government Resources
- Medicare Learning Network (MLN): cms.gov/training-education/medicare-learning-network-mln
- Medicare Managed Care Manual, Chapter 21: Available at cms.gov
- Prescription Drug Benefit Manual, Chapter 9: Available at cms.gov
- OIG Compliance Guidance: oig.hhs.gov/compliance/compliance-guidance
Internal Resources
Nivano Physicians staff have access to:
- Policy and procedure manuals specific to our operations
- Case studies and real-world compliance scenarios
- Quick reference guides for daily operations
- Compliance checklists and workflow tools
- CMS memo and guidance tracking updates
Documentation and Record Retention
All training records are maintained in accordance with CMS requirements and the Nivano Physicians Data Retention Policy.
| Record Type | Retention Period |
|---|---|
| Individual training completion records | 10 years from completion |
| FDR attestation records | 10 years from date of attestation |
| Course materials and curricula | Current version plus 3 years |
| Competency assessment and certification records | 10 years from issuance |
| Training program audit records | 10 years from completion |
Training Effectiveness and Oversight
The Compliance Officer is responsible for:
- Ensuring all staff and applicable FDRs complete required training within mandated timeframes
- Monitoring completion rates and following up on gaps
- Updating training content annually to reflect regulatory changes
- Reporting training status to the Board of Directors and Compliance Committee
- Coordinating CMS audit preparation and documentation
Training effectiveness is evaluated through pre- and post-training assessments, compliance monitoring, and annual audit results. Employees who do not complete required training by the applicable deadline are subject to remedial training requirements and escalation per Nivano Physicians’ disciplinary procedures.
Contact Information
For questions about this training program or to submit FDR training completion documentation:
Compliance Department — Nivano Physicians, Inc.
2554 Millcreek Dr., Suite 100, Sacramento, CA 95833
Phone: (916) 407-2000
Toll Free: (844) 889-2273
Email: compliance@nivanophysicians.com
Provider Services hours: Monday – Friday, 8:00 a.m. – 5:00 p.m. PST
Policy Review
This page is reviewed annually and updated to reflect current CMS requirements, MLN module availability, and any changes to FDR training obligations. The next scheduled review is March 12, 2027.
This policy was last approved on March 12, 2026 by the Compliance Department.