CMS Training Requirements: A 2025 Guide for All CMS Training Programs

In 2025, CMS training requirements became more detailed and expansive, placing increased pressure on compliance professionals, healthcare administrators, and provider organizations to stay ahead of evolving standards. Failure to comply can result in severe consequences, including payment denials, civil monetary penalties, or even exclusion from federal programs.

While many compliance solutions offer basic training tracking, only a truly comprehensive platform can manage the full scope of CMS training requirements, ensure timely completion across departments, and maintain defensible audit records. Compliancy Group software is designed to do exactly that, delivering an automated, scalable, and CMS-aligned training compliance solution that supports your team every step of the way.

This guide breaks down what CMS training requirements include, who must complete them, what is new for 2025, and how Compliancy Group can simplify compliance for healthcare organizations of all sizes.

What Are the CMS Training Requirements?

CMS training requirements are a cornerstone of regulatory compliance for healthcare organizations that participate in federal programs such as Medicare, Medicaid, CHIP, and the Quality Payment Program (QPP). These mandatory trainings are designed to ensure that healthcare providers and their staff understand the rules, responsibilities, and ethical standards required to deliver safe, effective, and compliant care.

At their core, CMS training requirements aim to:

• Promote awareness of fraud, waste, and abuse (FWA)
• Support proper billing, coding, and documentation practices
• Educate staff on compliance and ethics obligations
• Reinforce program-specific rules and quality expectations

As of 2025, CMS outlines several essential training areas that providers must address:

1. General Compliance Training

This foundational training introduces employees and contractors to CMS’s core compliance standards. It covers topics such as proper billing procedures, whistleblower protections, identifying potential violations, and understanding the roles of compliance officers. It must be completed within 90 days of hire or contract initiation and annually thereafter.

2. Fraud, Waste, and Abuse (FWA) Training

FWA training is required for entities involved in Medicare Parts C and D, including Medicare Advantage Organizations (MAOs), Prescription Drug Plans (PDPs), and their First-Tier, Downstream, and Related Entities (FDRs). This training educates staff on laws such as the False Claims Act, Anti-Kickback Statute, and Stark Law. Like general compliance training, FWA training must be completed within 90 days of onboarding and annually thereafter.

3. Role-Specific and Program-Specific Training

CMS also requires tailored training for individuals working in certain roles or settings. For example:

• Appeals and grievance staff must complete CMS-specific training related to the handling of complaints and coverage determinations.
• Employees in long-term care facilities must receive education on communication, resident rights, abuse prevention, and infection control as mandated by 42 CFR §483.95.

4. State-Specific and Medicaid Requirements

Medicaid and CHIP programs often impose additional state-level training modules. These may include education on eligibility verification, provider enrollment rules, and home-and-community-based services (HCBS) compliance.

5. Documentation and Record Retention

CMS mandates that providers retain records of completed training, including certificates of completion or signed attestations. These records must be available for inspection and typically must be retained for at least 10 years. Compliance officers must ensure documentation is up-to-date and accessible for CMS audits.

In summary, CMS training requirements are not optional; they are a critical regulatory obligation that applies across provider types, job functions, and program participation. A comprehensive training program, backed by automated tracking and documentation, is essential for staying compliant and avoiding costly penalties.

Who Must Complete CMS Training?

CMS training requirements apply broadly across the healthcare industry, not just to physicians and clinicians, but also to a wide range of personnel, organizations, and partners. If an individual or entity has a direct or indirect role in delivering or supporting CMS program services, they are likely required to complete CMS-mandated training.

Below is a breakdown of who is responsible for compliance training.

Medicare-Enrolled Providers

Any individual or organization enrolled in Medicare Part A or B is subject to CMS general compliance training. This includes physicians, hospitals, outpatient clinics, skilled nursing facilities, and other covered entities. Training must be completed within 90 days of hire or engagement, and repeated annually.

Medicare Advantage (Part C) and Part D Sponsors

Organizations that manage Medicare Advantage or Prescription Drug Plans must ensure all staff, including executives, contractors, and downstream entities, complete both General Compliance and FWA Training. CMS requires these sponsors to monitor compliance and maintain training documentation for at least 10 years.

First-Tier, Downstream, and Related Entities (FDRs)

FDRs, including third-party billing services, call centers, IT vendors, and delegated administrative services, are required to follow the same training standards as their Medicare plan sponsors. These organizations must also maintain training logs, signed attestations, and an audit trail to demonstrate compliance.

Hospitals, Clinics, and Long-Term Care Facilities

Staff in institutional healthcare settings are subject to CMS’s regulatory training under 42 CFR §483.95. Required training areas include:

• Effective communication
• Residents’ rights
• Quality assurance and performance improvement (QAPI)
• Abuse prevention and reporting
• Infection control
• Ethics and compliance programs

Facilities must also provide ongoing annual in-service training and may need to tailor training based on staff roles and facility accreditation requirements.

Nurse Aides and Feeding Assistants

Under CMS guidelines, nurse aides must complete at least 75 hours of state-approved training, including supervised clinical experience and annual in-service education. Paid feeding assistants must also meet competency requirements as defined in Subpart D of §483.

Contractors, Volunteers, and Vendors

CMS expects organizations to ensure that all personnel who contribute to patient care or administrative functions—whether employed, contracted, or volunteering, receive appropriate training. This includes part-time staff, consultants, and temporary workers.

Medicaid and CHIP Providers

Training requirements for Medicaid and CHIP vary by state but often mirror Medicare’s foundational standards. Some states mandate specialized education for home-and community-based services (HCBS), telehealth services, or managed care organizations (MCOs).

QPP / MIPS Participants

Providers participating in the Quality Payment Program (QPP) or Merit-Based Incentive Payment System (MIPS) must understand CMS’s rules on reporting, promoting interoperability, and avoiding penalties for data submission errors or non-compliance.

Bottom Line:
From small private practices to nationwide health systems, CMS training requirements touch virtually every corner of the healthcare delivery ecosystem. Ensuring that the right people receive the right training at the right time is essential for compliance, audit readiness, and patient safety. 

Key CMS Training Requirements by Program (2025 Update)

CMS training requirements are not one-size-fits-all. While foundational compliance and fraud training apply broadly, different CMS programs impose additional training expectations based on provider type, care setting, and program participation. In 2025, updates reflect CMS’s heightened focus on data integrity, care quality, and patient protections, making it more critical than ever for healthcare organizations to understand program-specific requirements.

A. Medicare Providers (Parts A & B)

Medicare-enrolled providers are required to complete both General Compliance Training and, where applicable, Fraud, Waste, and Abuse (FWA) Training. These trainings must be completed within 90 days of hire or contracting, and repeated annually. In addition, providers must be trained in documentation accuracy, billing compliance, and maintaining updated credentials.

Medicare Advantage (Part C) and Part D sponsors must ensure that all staff, including contractors and First-Tier, Downstream, and Related Entities (FDRs), complete CMS-specified training and attest to their participation. These entities must also retain proof of training for 10 years and be able to produce it during audits.

B. Medicaid & CHIP Providers

While Medicaid is a state-administered program, CMS requires that Medicaid and CHIP providers comply with state-specific training mandates, which often mirror federal Medicare guidelines. These may include:

• Cultural competency training
• Eligibility verification training
• Enrollment and billing compliance
• State-specific fraud prevention requirements

Additionally, states that offer Home-and-Community-Based Services (HCBS) must ensure that provider staff complete training modules related to individualized care plans, conflict-free case management, and person-centered care models.

C. Quality Payment Program (QPP) / MIPS Participants

Providers participating in QPP or the Merit-Based Incentive Payment System (MIPS) must understand their responsibilities for reporting clinical quality measures, promoting interoperability, and maintaining audit-ready records. CMS encourages regular training on:

• Data submission and attestation procedures
• Security and privacy of electronic health records (EHR)
• CMS audit procedures and penalties for misreporting

Failure to adequately train staff may result in lower MIPS composite scores and reduced reimbursement.

D. State-Specific and Facility-Based Training

In long-term care facilities and hospitals, CMS regulations under 42 CFR §483.95 require annual in-service training in resident rights, infection control, and abuse prevention. Other facilities, such as federally qualified health centers (FQHCs) and rural health clinics (RHCs) must also ensure staff meet training requirements tied to their certification and billing privileges.

Key Takeaway:
CMS’s program-specific training requirements reflect the complexity of today’s healthcare landscape. Staying compliant means staying informed, and using a platform like Compliancy Group helps providers ensure that no training requirement falls through the cracks.

CMS Training Frequency, Deadlines, and Documentation

Meeting CMS training requirements is not just about what content is delivered; it is also about when it is completed and how well it is documented. CMS provides specific expectations for training frequency, onboarding timelines, and record retention, all of which are essential for passing audits and avoiding penalties.

Training Frequency and Timelines

CMS mandates that General Compliance and FWA training must be completed:

• Within 90 days of hire or contracting, and
• Annually thereafter

This requirement applies across Medicare Parts A, B, C, and D participants, including First-Tier, Downstream, and Related Entities (FDRs). Failure to meet these timelines can place organizations out of compliance and subject to corrective action plans or exclusion from federal programs.

For Medicaid and CHIP providers, training frequency may vary slightly depending on state-specific mandates. However, most states follow similar annual or onboarding-based timeframes, especially for core training topics like billing integrity, eligibility, and HCBS compliance.

Additionally, long-term care facilities must provide ongoing in-service training, as required by 42 CFR §483.95, ensuring staff remain updated on infection control, abuse prevention, and resident rights.

Documentation and Record Retention

CMS requires that organizations retain records of training completion, including:

• Certificates of completion
• Signed employee attestations
• Dates of training delivery
• Role-specific learning assignments

These records must be kept for at least 10 years and be readily accessible for CMS or Medicare Advantage Organization (MAO) audits. Digital documentation and centralized training logs are considered best practices.

How Compliancy Group Helps

Compliancy Group simplifies these obligations by automating training reminders, tracking completions in real-time, and maintaining a defensible audit trail. Administrators can easily verify who has completed required training and produce documentation instantly during compliance reviews.

Consequences of Non-Compliance with CMS Training Requirements

Failing to meet CMS training requirements is not a minor oversight. It can lead to serious legal, financial, and operational consequences for healthcare organizations. CMS holds providers, vendors, and affiliated entities accountable for ensuring that all applicable staff are properly trained. When training obligations are ignored or poorly documented, the risks escalate quickly.

1. Financial Penalties and Reimbursement Loss

Non-compliant organizations may face civil monetary penalties and repayment demands for improperly billed claims. In severe cases, CMS may suspend or deny Medicare or Medicaid reimbursements altogether, directly affecting revenue and financial stability.

2. Exclusion from Federal Programs

Continued failure to adhere to training regulations can lead to temporary or permanent exclusion from participating in federal healthcare programs. This applies not only to organizations, but also to individual providers or subcontractors who violate CMS rules.

3. Increased Audit and Oversight Risk

CMS, Medicare Advantage plans, and state Medicaid agencies frequently audit training compliance as part of their broader program integrity reviews. Missing documentation, outdated training logs, or insufficient employee attestation can trigger corrective action plans (CAPs) or contract terminations.

4. Reputational Damage and Operational Disruption

Beyond penalties and audits, non-compliance damages your reputation with regulators, payers, and patients. It can also disrupt daily operations as leadership diverts resources to handle investigations, retraining, and remediation.

In short: Non-compliance with CMS training mandates is costly, risky, and avoidable. With Compliancy Group, healthcare organizations can reduce risk by ensuring all training is timely, verifiable, and aligned with CMS standards.

Common Challenges in Managing CMS Training

Even the most well intentioned healthcare organizations can struggle to maintain CMS training compliance. As regulatory requirements grow more complex and staff turnover increases, managing training across departments, locations, and roles becomes increasingly difficult without a robust system in place.

1. Tracking Training Across Multiple Sites and Roles

Large organizations often operate across multiple facilities and states, each with different requirements based on program type (e.g., Medicare vs. Medicaid) and employee roles. Without a centralized platform, tracking who has completed which training, and when, is a logistical headache that introduces risk.

2. Onboarding New Hires and Contractors

CMS requires that training be completed within 90 days of hire or contracting. In fast-paced healthcare settings, onboarding timelines can slip, leaving new staff non-compliant and the organization vulnerable to audit penalties.

3. Outdated or Inconsistent Training Content

CMS training standards evolve regularly. Organizations relying on outdated modules, generic templates, or manually updated files may unintentionally fall out of compliance. Additionally, training must be tailored by role and program, something generic solutions often fail to address.

4. Incomplete Documentation and Audit Readiness

Paper sign-in sheets, spreadsheets, or decentralized tracking systems are prone to error and difficult to reconcile during an audit. Missing records, incomplete attestations, or inaccurate logs can result in failed audits, even when the training was actually completed.

5. Staff Fatigue and Low Engagement

If training is repetitive, irrelevant to employees’ roles, or delivered inefficiently, staff may disengage. Low engagement reduces retention of critical information and increases the risk of compliance violations in day-to-day operations.

Compliancy Group addresses these challenges head-on with automated workflows, up-to-date training modules, real-time dashboards, and centralized documentation, giving compliance officers confidence in their CMS training program.

How Compliancy Group Solves These Challenges

Compliancy Group goes beyond basic compliance tracking, offering an intelligent, all-in-one solution that simplifies and strengthens your organization’s approach to CMS training requirements. Whether you are managing a single practice or a multi-state healthcare system, Compliancy Group provides the tools you need to stay compliant, reduce risk, and streamline administration.

1. Centralized, Role-Based Training Management

With Compliancy Group’s intuitive dashboard, compliance officers can assign role-specific training modules.

2. Automated Tracking, Reminders, and Attestations

Manual tracking leads to missed deadlines and audit stress. Compliancy Group automates:

• Training delivery
• Deadline reminders
• Employee attestations
• Renewal cycles

Administrators receive alerts when deadlines are approaching or training is overdue—ensuring no staff member falls through the cracks.

3. Up-to-Date, CMS-Aligned Content

CMS rules change frequently. Compliancy Group continuously updates training content in accordance with federal and state regulations, so your organization is always working with current material. 

4. Real-Time Audit Readiness

All training records including certificates, completion logs, and employee attestations, are securely stored and accessible on demand. During an audit, you can instantly generate reports proving training completion across individuals, departments, or locations. No more scrambling through spreadsheets or paper files.

5. Scalable for Any Size Organization

Whether you are a solo provider, a large health system, or a third-party FDR, Compliancy Group adapts to your needs. Multi-location support, flexible user roles, and cloud-based access make it easy to manage training compliance, even for organizations with hundreds or thousands of employees.

The result: Less time spent chasing compliance. More confidence during audits. And complete peace of mind knowing your CMS training obligations are met, accurately and on time.

Best Practices for CMS Training Compliance

Compliance with CMS training requirements does not happen by accident; it requires a structured, proactive approach supported by clear processes and the right tools. Healthcare organizations that implement the following best practices are better prepared for audits, reduce regulatory risk, and foster a stronger culture of compliance across all levels.

1. Implement Role-Specific Learning Paths

Training should be tailored to individual responsibilities. A nurse aide, a billing specialist, and an executive all have different compliance obligations. Design customized training tracks based on role, department, and CMS program participation (e.g., Medicare Part D vs. Medicaid HCBS).

2. Automate Training Assignment and Reminders

Manual training coordination is time-consuming and error-prone. Automating training assignment, deadline notifications, and reminders ensures no staff member misses a required course—especially during onboarding or annual recertification periods.

3. Maintain Centralized, Accessible Records

CMS auditors may request proof of training at any time. Keep all training certificates, attestations, and logs in a single, cloud-accessible system with real-time tracking and reporting capabilities.

4. Update Content Regularly

CMS guidelines evolve annually. Ensure your training modules reflect the latest federal and state requirements. Subscribe to CMS updates or partner with a compliance platform that continuously refreshes content based on current regulations.

5. Conduct Internal Training Audits

Regularly review your organization’s training completion rates, overdue assignments, and documentation accuracy. These internal checks help identify gaps before CMS or state agencies do.

6. Provide Engaging, Interactive Training

Boost retention and engagement by offering training that is relevant, interactive, and easy to complete. When staff understand the why behind compliance, adherence improves.

By following these best practices, and leveraging a platform like Compliancy Group, healthcare organizations can transform CMS training from a burden into a strategic advantage.

Conclusion and Next Steps

In today’s regulatory environment, meeting CMS training requirements is more than a checkbox; it is a critical element of protecting your organization, your patients, and your reputation. From Medicare and Medicaid to CHIP and QPP, CMS mandates a wide range of training obligations that vary by role, program, and setting. Staying ahead of these requirements demands not only awareness but also organization-wide coordination, timely execution, and reliable documentation.

Non-compliance can lead to steep consequences—lost reimbursement, civil penalties, increased audit risk, and even exclusion from federal programs. Yet for many organizations, the challenge lies in managing these requirements consistently across departments, facilities, and contractors.

That is where Compliancy Group comes in:

Our platform simplifies CMS training compliance through:

• Automated delivery and tracking
• Role-specific content updated in real time
• Centralized documentation for audit readiness
• Scalable support for multi-location providers and health systems

Whether you are a compliance officer, administrator, or provider leader, Compliancy Group helps you streamline your compliance efforts so you can focus on delivering excellent care.

Next Steps:

• Review your current CMS training program for gaps
• Evaluate whether your documentation is complete and audit-ready
• Schedule a demo with Compliancy Group to see how we can take the burden off your team