Introduction
During onboarding, and before access to any HCQIS system or application, each user must sign Rules of Behavior, complete the appropriate training, and provide evidence of training completion to their Security Point of Contact (SPOC); the SPOC will track all required training within their organization. In many cases, an annual attestation is also provided to the organization’s CMS Contracting Officer’s Representative (COR) as a deliverable.
If you have questions about policy or need more information regarding contract requirements, please contact your COR
Please view information on the following topics below: Training, Local SPOC/SO SAT Certification/Attestation, SAT Record Keeping and Maintenance for SPOCs , and Previous HCQIS Contractors vs New Users .
During onboarding and before access to any HCQIS system or application each user must complete proper training requirements on an annual basis and must provide evidence of completion to his/her respective Security Point of Contact (SPOC) who will track all required training within the organization.
Note: In most cases, an annual attestation is also provided to the CMS COR as a deliverable. Contact your COR for specific contract deliverables and dates.
Security Awareness Training
The HCQIS system utilizes the DoD Cyber Exchange (h ttps://public.cyber.mil/cyber-training/), a publicly accessible training library with course offerings to allow Contractors to meet the CMS SAT requirements. These trainings include the C yber Awareness Challenge and Identifying and Safeguarding Personable Identifiable Information (PII) Privacy Training.
Records Management
The Department of Health and Human Services (HHS) Records Management training is a mandatory training requirement and is outlined in the HHS Policy for Records Management and the Office of Management and Budget (OMB) and National Archives and Records Administration (NARA) Directive M-19-21, Transition to Electronic Records. The purpose of this training is to provide an overview of employee responsibilities for records management, help employees tell the difference between records and non-records, and assist employees in learning how to manage the federal records lifecycle.
Note: HHS Human Capital manages Records Management training and requirements for CMS. Therefore, separate or updated instructions may be sent by HHS which include updates to training links, requirements or content and should be used as underlining guidance outside of these instructions. Please check with your COR on for any changes to these requirements.
Below are the links to the websites where the three required trainings are hosted. DoD provides the links for the security trainings and are subject to change at any time. If a link is broken, you may also do a web search for the name of the training and use the appropriate search result since they are publicly available.
User Instructions
- Complete the online trainings as defined by the deliverable, contract onboarding period or other timeframe identified by the program/contract.
- Enter your name in the Certification of Completion’s online display, which is provided at the successful conclusion of the training.
- Note: Screen captures Training certificate are acceptable if no printable certificate exists or if any errors occur while printing.
- Take a screen capture (shot) or save a copy of the certificate locally then provide a copy of your completed certification to your organization’s assigned Security Point of Contact (SPOC) who will maintain a copy for record retention.
The SPOC should adhere to the following guidelines related to certification and attestation of training results:
- Only one memo is required for all sites under each prime contract region/area/site.
- The Certification Memo must be signed by the SPOC (or in the SPOC’s absence, the Security Officer (SO)) and the organization’s designated Program Lead.
- You may apply a naming convention that best suits your organization, Contract or deliverable, but that is easy to understand by other readers.
- Submit the completed certification memo electronically to you’re COR using the specified vehicle outlined in the contract as directed by the CMS COR.
Organizational SPOCs may leverage the provided template to fulfill the requirement.
QNet Security Awareness Certification Template.docx
Records must be updated and maintained at all times, but they are only to be submitted to CMS if requested by the COR or the Information Systems Security Officer (ISSO). Record templates are available within the Security page on the QualityNet Communications Hub or may be obtained through your CMS COR.
Contracts operating across multiple sites (prime/sub) may exercise the option of having multiple records or a single record that reflects all individual sites and each user respectively.
At the top of each page insert the Contract name and specify the site if applicable. For multiple sites in a single area, you may use a different table that identifies each State/region for each site.
Organizational SPOCs may leverage the provided template to fulfill the requirement.
Security Awareness Training Record template.docx
New users on a contract take training at the time of receiving initial access and annually thereafter. Some contracts and organizations require all users to complete training by a specific time each year. With this, there may be times where an user has transferred from another contract or has recently started and would NOT have to re-take the training again. Therefore, if a user has started or transferred and has taken all required trainings within the last 90 days, that user may be except from taking any training again until the following calendar year or deliverable period; whichever schedule is followed.