Developed by the Centers for Medicare & Medicaid Services* *Health plan specific information added with permission from CMS.

Transcription

1 Medicare Parts C & D General Compliance Training Developed by the Centers for Medicare & Medicaid Services* *Health plan specific information added with permission from CMS.

2 Important Notice The Health Plan is a Medicare Part C & D Sponsor. All contractors of Part C & D Sponsors who provide health or administrative services to Medicare enrollees must satisfy general compliance training requirements in accordance with Compliance Program regulations at 42 C.F.R (b)(4)(vi) and (b)(4)(vi) and in Section 50.3 of the Compliance Program Guidelines found in Chapter 9 of the Medicare Prescription Drug Benefit Manual and Chapter 21 of the Medicare Managed Care Manual. Completion of this training module satisfies the 2013 annual requirement for Medicare Parts C & D General Compliance Training.

3 Why Do I Need Training? Compliance is EVERYONE S responsibility! As an individual who provides health or administrative services for Medicare enrollees, every action you take potentially affects Medicare enrollees, the Medicare program, or the Medicare trust fund.

4 Where Do I Fit In? Health or administrative services to a Part C or Part D enrollee are provided by either a: Part C or D Sponsor Employee First Tier Entity Examples: PBM, a Claims Processing Company, contracted Sales Agent Downstream Entity Example: Pharmacy Related Entity Example: Entity that has a common ownership or control of a Part C/D Sponsor The Health Plan is a Part C & D Sponsor.

5 Training Objectives To understand the organization s commitment to ethical business behavior To understand how a compliance program operates To gain awareness of how compliance violations should be reported

6 Background CMS requires Medicare Advantage, Medicare Advantage Prescription Drug, and Prescription Drug Plan Sponsors ( Sponsors ) to implement an effective compliance program. An effective compliance program should: Provide guidance on how to handle compliance questions and concerns Provide guidance on how to identify and report compliance violations Articulate and demonstrate an organization s commitment to legal and ethical conduct

7 Compliance A culture of compliance within an organization: Prevents noncompliance Detects noncompliance Corrects noncompliance

8 Compliance Program Requirements At a minimum, a compliance program must include the 7 core requirements: 1. Written Policies, Procedures and Standards of Conduct; 2. Compliance Officer, Compliance Committee and High Level Oversight; 3. Effective Training and Education; 4. Effective Lines of Communication; 5. Well Publicized Disciplinary Standards; 6. Effective System for Routine Monitoring and Identification of Compliance Risks; and 7. Procedures and System for Prompt Response to Compliance Issues 42 C.F.R (b)(4)(vi) and (b)(4)(vi); Internet Only Manual ( IOM ), Pub , Medicare Managed Care Manual Chapter 21; IOM, Pub , Medicare Prescription Drug Benefit Manual Chapter 9

9 Compliance Officer As Requirement Two states, Plans must have a Medicare Compliance Officer. The Medicare Compliance Officer is Jill Salerno. Jill can be reached at: 165 Court St. Rochester, NY (585) or via the Ethics & Compliance Hotline (800) Jill Salerno

10 Compliance Training CMS expects that all Sponsors will apply their training requirements and effective lines of communication to the entities with which they partner. Having effective lines of communication means that employees of the organization and the partnering entities have several avenues through which to report compliance concerns.

11 Ethics Do the Right Thing! Act Fairly and Honestly Comply with the letter and spirit of the law As a part of the Medicare program, it is important that you conduct yourself in an ethical and legal manner. It s about doing the right thing! Adhere to high ethical standards in all that you do Report suspected violations

12 How Do I Know What is Expected of Me? Know the Code! The Code of Business Conduct states compliance expectations and the principles and values by which the organization operates. Everyone is required to report violations of our Code of Conduct and suspected noncompliance. The Code of Conduct and Policies and Procedures identify this obligation and tell you how to report.

13 What Is Noncompliance? Noncompliance is conduct that does not conform to the law, and Federal health care program requirements, or to our ethical and business policies. Credentialing Ethics Appeals and Grievance Review HIPAA Claims Processing Marketing and Enrollment Medicare Parts C & D High Risk Areas * Conflicts of Interest Beneficiary Notices Agent / Broker Documentation Requirements *For more information, see the Medicare Managed Care Manual and the Medicare Prescription Drug Benefit Manual at Quality of Care Formulary Administration

14 Noncompliance Harms Enrollees Delayed services Denial of Benefits Without programs to prevent, detect and correct noncompliance there are: Difficulty in using providers of choice Hurdles to care

15 Noncompliance Costs Money Non Compliance affects EVERYBODY! Without programs to prevent, detect and correct noncompliance we risk: Higher Premiums Higher Insurance Copayments Exclusion from Federal Health Care programs Lower benefits for individuals and employers Lower Star ratings

16 I m Afraid to Report Noncompliance There can be NO retaliation against you for reporting suspected noncompliance in good faith. The Plan offers reporting methods that are: Confidential Anonymous Non Retaliatory

17 How Can I Report Potential Noncompliance? Contact the Medicare Compliance Officer Call the Ethics & Compliance Hot Line 800 ASK 0170 Send a message to the Ethics & Compliance box in Lotus Notes Call the Special Investigations Unit to report Fraud, Waste and Abuse Talk to your Manager or Supervisor First tier, downstream, and related entities (FDR) can call the Ethics & Compliance Hot Line, speak to a Manager or Supervisor or contact the sponsor (Health Plan) Beneficiaries of all lines of business can call the Ethics & Compliance Hot Line Medicare beneficiaries can also call 800 Medicare

18 What Happens Next? After noncompliance has been detected It must be investigated immediately And then promptly correct any noncompliance Correcting Noncompliance Avoids the recurrence of the same noncompliance Promotes efficiency and effective internal controls Protects enrollees Ensures ongoing compliance with CMS requirements

19 How Do I Know the Noncompliance Won t Happen Again? Once noncompliance is detected and corrected, an ongoing evaluation process is critical to ensure the noncompliance does not recur. Monitoring activities are regular reviews which confirm ongoing compliance and ensure that corrective actions are undertaken and effective. Auditing is a formal review of compliance with a particular set of standards (e.g., policies and procedures, laws and regulations) used as base measures Monitor/ Audit Correct Prevent Report Detect

20 Know the Consequences of Noncompliance Plans are required to have disciplinary standards in place for non compliant behavior. Those who engage in non Compliant behavior may be subject to any of the following: Mandatory Training or Re Training Disciplinary Action Termination

21 Compliance is EVERYONE S Responsibility!! PREVENT Operate within our organization s ethical expectations to PREVENT noncompliance! DETECT & REPORT If you DETECT potential noncompliance, REPORT it! CORRECT CORRECT noncompliance to protect beneficiaries and to save money!

22 What Governs Compliance? Social Security Act: Title 18 Code of Federal Regulations*: 42 CFR Parts 422 (Part C) and 423 (Part D) CMS Guidance: Manuals HPMS Memos CMS Contracts: Private entities apply and contracts are renewed/non renewed each year Other Sources: OIG/DOJ (fraud, waste and abuse (FWA)) HHS (HIPAA privacy) State Laws: Licensure Financial Solvency Sales Agents * 42 C.F.R (b)(4)(vi) and (b)(4)(vi)

23 Additional Resources For more information on laws governing the Medicare program and Medicare noncompliance, or for additional healthcare compliance resources please see: Title XVIII of the Social Security Act Medicare Regulations governing Parts C and D (42 C.F.R. 422 and 423) Civil False Claims Act (31 U.S.C ) Criminal False Claims Statute (18 U.S.C. 287,1001) Anti Kickback Statute (42 U.S.C. 1320a 7b(b)) Stark Statute (Physician Self Referral Law) (42 U.S.C. 1395nn) Exclusion entities instruction (42 U.S.C. 1395w 27(g)(1)(G)) The Health Insurance Portability and Accountability Act of 1996 (HIPAA) (Public Law ) (45 CFR Part 160 and Part 164, Subparts A and E) OIG Compliance Program Guidance for the Healthcare Industry: guidance/index.asp

24 Remember! Compliance is EVERYONE S responsibility There can be NO retaliation against you for reporting suspected noncompliance in good faith. To report, call the Hotline at (800) ASK 0170

25 Contractor Medicare General Compliance Training Test Questions 1. What is conduct that does not conform to the law, and Federal health care program requirements, or to our ethical and business policies? a. Noncompliance b. Compliance c. Ethics d. None of these 2. What are the benefits of a culture of compliance within an organization? a. To prevent noncompliance b. To detect noncompliance c. To correct noncompliance d. All of the above 3. Without programs to prevent, detect and correct noncompliance we risk? a. Higher Star Ratings b. Lower Premiums c. Lower Insurance Copayments d. Exclusion from Federal Health Care programs 4. True or false We offer reporting methods that are confidential, anonymous and non retaliatory? a. True b. False 1

26 5. At a minimum, a compliance program must include 7 core requirements. Which of the following are core requirements? a. Effective Training and Education b. Procedures and System for Prompt Response to Compliance Issues c. Well Publicized Disciplinary Standards d. Effective System for Routine Monitoring and Identification of Compliance Risks e. All of the above 6. You have discovered an unattended address or fax machine in your office which receives beneficiary appeals requests. You suspect that no one is processing the appeals. What should you do? a. Contact Law Enforcement b. Contact your Compliance Department c. Wait to confirm someone is processing the appeals before taking further action d. Contact your supervisor 7. A sales agent, employed by the one of our first tier or downstream entities, has submitted an application for processing and has requested the enrollment date be back dated by one month and all monthly premiums for the beneficiary be waived What should you do? a. Refuse to change the date or waive the premiums, but decide not to mention the request to a supervisor or the compliance department. b. Make the requested changes because the sales agent is responsible for determining the beneficiary's start date and monthly premiums. c. Tell the sales agent you will take care of it, but then process the application properly (without the requested revisions). You will not file a report because you don't want the sales agent to retaliate against you. d. Process the application properly (without the requested revisions). Inform your supervisor and the compliance officer about the sales agent's request. 2

27 8. Last month, while reviewing a monthly report from CMS, you identified multiple enrollees for which we are being paid, who are not enrolled in our plan. You spoke to your supervisor, Tom, who said not to worry about it. This month, you have identified the same enrollees on the report again. What do you do? a. Decide not to worry about it as your supervisor, Tom, had instructed. You notified him last month and now it s his responsibility. b. Although you have seen notices about our non retaliation policy, you are still nervous about reporting. To be safe, you submit a report through your Compliance Department s anonymous tip line so that you cannot be identified. c. Contact law enforcement and CMS to report the discrepancy. d. Ask Tom about the discrepancies again. 9. True or false As a Part C & D Sponsor, we are required to have a compliance committee to oversee our compliance program; however, the hiring or appointment of a compliance officer is optional. a. True b. False 10. TRUE OR FALSE: If we subcontract with downstream entities for the performance of services, the downstream entity is ultimately responsible for complying with all CMS requirements. a. True b. False 3

28 Fraud, Waste and Abuse Training Developed by the Centers for Medicare & Medicaid Services* *Health plan specific information added with permission from CMS.

29 Important Notice The Health Plan is a Medicare Part C & D Sponsor. All Part C & D Sponsors employees must satisfy Fraud, Waste and Abuse training requirements. Completion of this training module satisfies the 2013 annual requirement for Fraud, Waste and Abuse Training.

30 Why Do I Need Training? Every year millions of dollars are improperly spent because of fraud, waste and abuse. It affects everyone. Including YOU. This training will help you detect, correct and prevent fraud, waste and abuse. YOU are part of the solution.

31 Objectives Meet the regulatory requirement for training and education Provide information on the scope of fraud, waste and abuse Explain everyone s obligation to detect, prevent and correct fraud, waste and abuse Provide information on how to report fraud, waste and abuse Provide information on laws pertaining to fraud, waste and abuse

32 Requirements The Social Security Act and CMS regulations and guidance govern the Medicare program, including parts C and D. Part C and Part D sponsors must have an effective compliance program which includes measures to prevent, detect and correct Medicare non compliance as well as measures to prevent, detect and correct fraud, waste and abuse. Sponsors must have an effective training for employees, managers and directors, as well as their first tier, downstream and related entities (FDRs). 42 C.F.R and 42 C.F.R

33 Where Do I Fit In? Health or administrative services to a Part C or Part D enrollee are provided by either a: Part C or D Sponsor Employee First Tier Entity Examples: PBM, a Claims Processing Company, contracted Sales Agent Downstream Entity Example: Pharmacy Related Entity Example: Entity that has a common ownership or control of a Part C/D Sponsor

34 What are my responsibilities? You are a vital part of the effort to prevent, detect and report Medicare non compliance as well as possible fraud, waste and abuse. FIRST you are required to comply with all applicable statutory, regulatory and other Part C or Part D requirements, including adopting and implementing an effective compliance program. SECOND you have a duty to the Medicare Program to report any violations of laws that you may be aware of. THIRD you have a duty to follow our organization s Code of Conduct that articulates your and our organization s commitment to standards of conduct and ethical rules of behavior.

35 An Effective Compliance Program Is essential to prevent, detect and correct Medicare non compliance as well as fraud, waste and abuse. Must, at a minimum, include the 7 core compliance program requirements. 42 C.F.R and 42 C.F.R

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37 How Do I Prevent Fraud, Waste and Abuse? Make sure you are up to date with laws, regulations, policies Ensure you coordinate with other payers Ensure data/billing is both accurate and timely Verify information provided to you Be on the lookout for suspicious activity

38 Policies and Procedures Every sponsor, first tier, downstream and related entity must have policies and procedures in place to address fraud, waste and abuse. These procedures should assist you in detecting, correcting, and preventing fraud, waste and abuse. Make sure you are familiar with the policies and procedures (P&Ps).

39 Our Policies and Procedures P&Ps are housed in and are available on Compliance homepage on the Intranet. Medicare P&Ps are available on the Medicare Compliance homepage on the Intranet. To the right is a screen shot of some of the Medicare Compliance P&Ps.

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41 Understanding Fraud, Waste and Abuse In order to detect fraud, waste and abuse you need to know the Law

42 Criminal FRAUD Knowingly and willfully executing, or attempting to execute, a scheme or artifice to defraud any health care benefit program; or to obtain, by means of false or fraudulent pretenses, representations, or promises, any of the money or property owned by, or under the custody or control of, any health care benefit program. 18 United States Code 1347

43 What Does That Mean? Intentionally submitting false information to the government or a government contractor in order to get money or a benefit.

44 Waste and Abuse Waste: overutilization of services, or other practices that, directly or indirectly, result in unnecessary costs to the Medicare Program. Waste is generally not considered to be caused by criminally negligent actions but rather the misuse of resources. Abuse: includes actions that may, directly or indirectly, result in unnecessary costs to the Medicare Program. Abuse involves payment for items or services when there is not legal entitlement to that payment and the provider has not knowingly and or/intentionally misrepresented facts to obtain payment.

45 Differences Between Fraud, Waste and Abuse There are differences between fraud, waste and abuse. One of the primary differences is intent and knowledge. Fraud requires the person to have an intent to obtain payment and the knowledge that their actions are wrong. Waste and abuse may involve obtaining an improper payment, but does not require the same intent and knowledge.

46 Report Fraud, Waste and Abuse Do not be concerned about whether it is fraud, waste or abuse. Just report any concerns to our Special Investigations Unit (SIU). The SIU will investigate and make the proper determination.

47 Indicators of Potential Fraud, Waste and Abuse Now that you know what fraud, waste and abuse are, you need to be able to recognize the signs of someone committing fraud, waste or abuse. The following slides demonstrate prescription drug issues to present examples of potential fraud, waste or abuse. Each slide provides areas to keep an eye on, depending on your role in our organization.

48 Key Indicators: Potential Provider Issues Does the provider write for diverse drugs or primarily only for controlled substances? Are the provider s prescriptions appropriate for the member s health condition (medically necessary)? Is the provider writing for a higher quantity than medically necessary for the condition? Is the provider performing unnecessary services for the member?

49 Key Indicators: Potential Beneficiary Issues Does the prescription look altered or possibly forged? Have you filled numerous identical prescriptions for this beneficiary, possibly from different doctors? Is the person receiving the service/picking up the prescription the actual beneficiary(identity theft)? Is the prescription appropriate based on beneficiary s other prescriptions? Does the beneficiary s medical history support the services being requested?

50 Key Indicators: Potential Pharmacy Issues Are we being billed for prescriptions that are not filled or picked up? Are drugs being diverted (drugs meant for nursing homes, hospice, etc. being sent elsewhere)?

51 Key Indicators: Potential Sponsor Issues Does the sponsor offer cash inducements for beneficiaries to join the plan? Does the sponsor lead the beneficiary to believe that the cost of benefits are one price, only for the beneficiary to find out that the actual costs are higher? Does the sponsor use unlicensed agents? Does the sponsor encourage/support inappropriate risk adjustment submissions?

52 How Do I Report Fraud, Waste or Abuse?

53 Reporting Fraud, Waste and Abuse Everyone is required to report suspected instances of fraud, waste and abuse. The Code of Conduct clearly states this obligation. The organization will not tolerate any form of retaliation against anyone who makes a good faith report in accordance with the Code.

54 Reporting Fraud, Waste and Abuse Every Part C & D Sponsor is required to have a mechanism in place in which potential fraud, waste or abuse may be reported by employees, first tier, downstream and related entities. You may report anonymously and you are protected from retaliation! When in doubt, call the Fraud Hotline ( ) or the Ethics & Compliance Hotline (800 ASK 0170).

55 Reporting Fraud, Waste and Abuse You may contact the Special Investigations Unit at the following location and numbers: 165 Court St. Rochester, NY Fraud Hotline: SIU Regional offices are as follows: Univera Rochester CNY Utica You may also report electronically by clicking on the Fraud & Abuse link at the bottom of the Excellusbcbs.com Home Page

56 Reporting Fraud, Waste and Abuse Additionally, you may contact the Chief Compliance Officer and/or the Medicare Compliance Officer at the following location and number: 165 Court St. Rochester, NY Ethics & Compliance Hotline: 800 ASK 0170 Employees may also submit s to the Corporate Compliance Officer at Ethics and Compliance through Lotus Notes. You may also contact the Corporate Legal Department via e tracker on Fingertips.

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58 Correction Once fraud, waste or abuse has been detected it must be promptly corrected. Correcting the problem saves the government money and ensures we are in compliance with CMS requirements.

59 How Do I Correct Issues? Once issues have been identified, a plan to correct the issue needs to be developed. Consult the Medicare Compliance Officer to learn about the process for the corrective action plan development. The actual plan is going to vary, depending on the specific circumstances.

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61 Laws The following slides provide very high level information about specific laws. For details about the specific laws, such as safe harbor provisions, consult the applicable statute and regulations concerning the law.

62 Civil Fraud Civil False Claims Act Prohibits: Presenting a false claim for payment or approval; Making or using a false record or statement in support of a false claim; Conspiring to violate the False Claims Act; Falsely certifying the type/amount of property to be used by the Government; Certifying receipt of property without knowing if it s true; Buying property from an unauthorized Government officer; and Knowingly concealing or knowingly and improperly avoiding or decreasing an obligation to pay the Government. 31 United States Code

63 New York State False Claims Act The New York State False Claims Act only applies to false claims submitted to the Medicaid program, and is very similar to the Federal False Claims Act. The New York State False Claims Act applies to persons who: 1. Knowingly submit a false or fraudulent claim to an employee, officer, or agent of the government; 2. Knowingly make a false record or statement to get a false claim paid by the state or local government; 3. Knowingly retain money owed to the government; 4. Knowingly make a false record or statement to conceal, avoid or decrease an obligation to pay money to the government; or 5. Conspire to get a false claim paid.

64 Medicare and Medicaid Program Integrity Statute In addition to potential liability under the State and Federal False Claims Acts for retaining an overpayment, health plans and providers can also be held liable for a failure to report, explain and return an overpayment to the government within 60 days of identifying it. This requirement was added as part of the federal health reform initiative. The requirement to timely report, explain and return an overpayment applies regardless of the reason for the overpayment. Even overpayments resulting from simple billing mistakes must be returned within 60 days.

65 False Claims Act Damages and Penalties Violations of the NY State False Claims Act can result in fines ranging from $6,000 to $12,000 per claim, plus three times the amount of damages sustained by the government. Violations of the Federal False Claims Act can result in civil penalties ranging from $5,500 to $11,000 per claim and up to triple the amount of damages sustained by the government. In both cases, exclusion from the Medicare and Medicaid program can also result.

66 Criminal Fraud Penalties If convicted, the individual shall be fined, imprisoned, or both. If the violations resulted in death, the individual may be imprisoned for any term of years or for life, or both. 18 United States Code 1347

67 Qui Tam The false claims act includes something called a Qui Tam provision. The Qui Tam provision allows people, also known as "whistleblowers," to hire a lawyer at their own expense and sue anyone they believe has defrauded the government. The government has the option of joining the suit as a party, which usually only occurs if they conclude the whistleblower has a good case. If the case is won, the whistleblower is entitled to a portion of the money recovered.

68 Protections under the FCA Just as we discuss in our own Code of Business Conduct, the Qui Tam provision prohibits retaliation against anyone who reports a False Claims Act violation. The Whistleblower Employee Protection Act prohibits an organization from discharging, demoting, suspending, threatening, harassing or discriminating against any employee because of lawful acts done by the employee, on behalf of the employer, or because the employee testifies or assists in an investigation of the employer. In addition, the False Claims Act provides a number of possible remedies to employees who are discharged, demoted, harassed, or otherwise discriminated against, because of lawful actions taken under the Act.

69 Anti Kickback Statute Prohibits: Knowingly and willfully soliciting, receiving, offering or paying remuneration (including any kickback, bribe, or rebate) for referrals for services that are paid in whole or in part under a federal health care program (which includes the Medicare program). Penalties: 42 United States Code 1320a 7b(b) Fine of up to $25,000, imprisonment up to five (5) years, or both fine and imprisonment.

70 Stark Statute (Physician Self Referral Law) Prohibits: A physician from making a referral for certain designated health services to an entity in which the physician (or a member of his or her family) has an ownership/investment interest or with which he or she has a compensation arrangement (exceptions apply). Penalties: 42 United States Code 1395nn Medicare claims tainted by an arrangement that does not comply with Stark are not payable. Up to a $15,000 fine for each service provided. Up to a $100,000 fine for entering into an arrangement or scheme.

71 Exclusion The Office of the Inspector General, the Office of the Medicaid Inspector General and the General Services Administration publish lists of individuals and companies who are excluded from doing business with the government. As a Health Plan with Medicare and Medicaid members, we may not employ or contract with individuals or companies that are excluded by these offices. This also applies to our first tier, downstream and related entities. We have a duty to verify, initially and monthly thereafter, that the individuals we hire, and the companies with which we contract, are not on the exclusion lists. Should an organization do business with an individual or company that it knew, or should have known, was excluded, the organization may face a civil monetary penalty of $10,000 for each claim submitted for any services or items that were furnished during the individual or company s exclusion, plus triple damages. 42 U.S.C. 1395(e)(1) 42 C.F.R

72 Health Insurance Portability and Accountability Act of 1996 (P.L ) Created greater access to health care insurance, protection of privacy of health care data, and promoted standardization and efficiency in the health care industry. Safeguards to prevent unauthorized access to protected health care information. As an individual who has access to protected health care information, you are responsible for adhering to HIPAA. Penalties: HIPAA civil penalties range from $100 per violation ($25,000 per year maximum) if the person did not know he/she was violating HIPAA to $50,000 per violation ($1,500,000 per year maximum) for violations due to willful neglect. HIPAA criminal penalties may be up to $50,000, with up to one year in prison. Add false pretenses to that and the penalties increase up to $100,000, and up to five years in prison. Adding intent to sell increases the penalties up to $250,000, with up to 10 years in prison.

73 Beneficiary Inducement Law Under the Beneficiary Inducement Law, it is illegal to offer items of value (cash, gift cards, goods and services, etc ), that a person knows (or should know), is likely to influence a potential customer/patient to select a particular provider, pharmacy or supplier. Violating the Beneficiary Inducement Law may result in fines of up to $10,000 per item or service, plus three times the damages incurred by the government. Violators also face potential exclusion from participation in government programs.

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75 Consequences of Committing Fraud, Waste or Abuse The following are potential penalties. The actual consequence depends on the violation. Civil Money Penalties Criminal Conviction/Fines Civil Prosecution Imprisonment Loss of Provider License Exclusion from Federal Health Care programs

76 Remember! You are a vital part of the effort to prevent, detect and report Medicare non compliance as well as possible fraud, waste and abuse. YOU are part of the solution.

77 Contractor FWA Training Test Questions 1. True or false there are no differences between fraud, waste and abuse. a. True b. False 2. True or false Every Part C & D sponsor is required to have a mechanism in place in which fraud, waste and abuse may be reported. a. True b. False 3. True or false CMS may not impose civil penalties for violations of fraud and abuse laws and regulations. a. True b. False 4. True or false Sponsors may not allow employees to report FWA activities anonymously. a. True b. False 5. True or false Fraud, waste and abuse affects you. a. True b. False 1