Compliance Program and Anti-Fraud Initiatives. Participant shall (and shall contractually require its Practice Providers and Suppliers to) institute, operate, and maintain an effective compliance program to detect, correct and prevent the incidence of non-compliance with Applicable Requirements and the incidence of fraud, waste and abuse relating to the MSSP and the federal healthcare program generally. Such compliance program shall be appropriate to Participant, Practice Providers’, or Supplier’s organization and operations and shall include:
a. Written policies, procedures and standards of conduct articulating the entity’s commitment to comply with federal and state laws; and
b. Provision of and required participation of all officers, directors, and employees in effective compliance and anti-fraud training and education that is consistent with guidance that CMS
Compliance Program and Anti-Fraud Initiatives. Provider shall (and shall cause its Downstream Entities to) institute, operate, and maintain an effective compliance program to detect, correct and prevent the incidence of non- compliance with CMS requirements and the incidence of fraud, waste and abuse (FWA) relating to the operation of HCS’s Medicare Program. Such compliance program shall be appropriate to Provider's or Downstream Entity's organization and operations and shall include:
1. written compliance policies and standards of conduct that are comparable to HCS’s compliance policies / HCS Code of Conduct and articulate the entity's commitment to comply with federal and state laws, ethical behavior and compliance program operations. Provider will disseminate either HCS’s compliance policies/HCS Code of Conduct or comparable versions to Provider's employees, officers, and Downstream Entities within 90 days of hire/contracting, when updates are made, and annually thereafter;
2. reporting mechanisms communicated to Provider's employees and Downstream Entities for their use in adhering to the expectation that Provider, its employees and its Downstream Entities report potential non- compliance or FWA issues (internally and to HCS, as applicable) and understand their obligation to report. Provider must publicize the reporting methods to Provider employees and Downstream Entities along with a no-tolerance policy for retaliation or retribution for good faith reporting;
3. completion of CMS' Medicare Learning Network® "Medicare Parts C and D Fraud, Waste, and Abuse Training and Medicare Parts C and D General Compliance Training" by Provider employees, officers, and Downstream Entities initially within ninety (90) days of hire/contracting and at least annually thereafter, unless exempt from such training under relevant CMS regulations. Training may be completed in one of two ways:
i. by completing the general compliance and FWA training modules located on the CMS Medicare Learning Network; ii. or by downloading, viewing or printing the content of the then current CMS standardized training modules from the HCS provider portal to incorporate into Provider's and/or Downstream Entity's organization's existing compliance training materials/systems. (The CMS training content may not be changed but Provider and/or its Downstream Entities may add to it to cover topics specific to its organization);
4. processes to oversee and ensure that Provider and Provider's Downstream Entities maintain compliance with processes ...
Compliance Program and Anti-Fraud Initiatives. Provider shall (and shall cause its Downstream Entities to) institute, operate, and maintain an effective compliance program to detect, correct and prevent the incidence of non-compliance with CMS requirements and the incidence of fraud, waste and abuse relating to the operation of Company’s Medicare Program. Such compliance program shall be appropriate to Provider or Downstream Entity’s organization and operations and shall include: (a) written policies, procedures and standards of conduct articulating the entity’s commitment to comply with Federal and State laws; and (b) for all officers, directors, employees, contractors and agents of Provider or Downstream Entity, required participation in effective compliance and anti-fraud training and education that is consistent with guidance that CMS has or may issue with respect to compliance and anti-fraud and abuse initiatives, unless exempt from such training under relevant CMS regulations.
Compliance Program and Anti-Fraud Initiatives. EIP shall develop and maintain an effective compliance program to detect, correct and prevent incidences of non-compliance with Applicable Requirements and incidences of fraud, waste and abuse relating to Model 4 and the federal healthcare program generally. Practice and Participating Physicians shall, and Practice shall contractually require its Providers to, comply with all requirements of EIP’s compliance program. EIP’s compliance program shall be appropriate to EIP’s operations, shall be in compliance with, and be updated periodically to reflect changes in, law and regulations, and shall include at least the following elements:
a. a designated compliance official or individual who is not legal counsel to the EIP and reports directly to the EIP’s governing body;
Compliance Program and Anti-Fraud Initiatives. Upline shall (and shall cause its subcontractors to) institute, operate, and maintain an effective compliance program to detect, correct and prevent the incidence of non-compliance with CMS requirements and the incidence of fraud, waste and abuse (FWA) relating to the operation of Aetna’s Medicare Program. Such compliance program shall be appropriate to Upline’s or subcontractor’s organization and operations and shall include:
(a) written policies, procedures and standards of conduct articulating the entity’s commitment to comply with federal and state laws, as well as providing mechanisms for employee/subcontractor use in adhering to the expectation that Upline and employee/subcontractor report potential non- compliance or FWA issues (internally and to Aetna, as applicable) ; (b) for all officers, directors, employees, contractors and agents of Upline or subcontractor, required participation in effective compliance and anti-fraud training and education that is consistent with guidance that CMS has or may issue with respect to compliance and anti-fraud and abuse initiatives, unless exempt from such training under relevant CMS regulations. This includes general compliance and FWA training completion, as well as code of conduct dissemination, initially within ninety (90) days of hire/contracting and at least annually thereafter; Upline and subcontractors, as applicable, may use Aetna’s code and training or an equivalent; and (c) processes to oversee subcontractors to ensure their compliance with these requirements. Upline Agreement 2015 47
Compliance Program and Anti-Fraud Initiatives. ACO shall develop and maintain an effective compliance program to detect, correct and prevent incidences of non-compliance with Applicable Requirements and incidences of fraud, waste and abuse relating to the MSSP and the federal healthcare program generally. Practice and Participating Physicians shall, and Practice shall contractually require its Providers to, comply with all requirements of ACO’s compliance program. ACO’s compliance program shall be appropriate to ACO’s operations, shall be in compliance with, and be updated periodically to reflect changes in, law and regulations, and shall include at least the following elements:
a. a designated compliance official or individual who is not legal counsel to the ACO and reports directly to the ACO’s governing body;
Compliance Program and Anti-Fraud Initiatives. Agent will (and will cause its subcontractors to) institute, operate and maintain an effective compliance program to detect, correct and prevent the incidence of non-compliance with CMS requirements and the incidence of fraud, waste and abuse (“FWA”) relating to the provision of services to Covered Persons. Such compliance program will be appropriate to Agent’s or subcontractor’s organization and operations. Agent will also comply with the terms of Plan’s FWA policies and procedures as set forth in the Plan’s policies and procedures. [42 C.F.R. §422.503(b)(vii)(C)]
Compliance Program and Anti-Fraud Initiatives. CompCare shall require CompCare Providers to undertake such compliance activities that may be required by CMS and/or that Health Plans determine is necessary for Health Plans to comply with their contracts with CMS and/or Applicable Law.
Compliance Program and Anti-Fraud Initiatives. Provider will (and will cause its subcontractors to) institute, operate and maintain an effective compliance program to detect, correct and prevent the incidence of non-compliance with CMS requirements and the incidence of fraud, waste and abuse (“FWA”) relating to the provision of services to Covered Persons. Such compliance program will be appropriate to Provider’s or subcontractor’s organization and operations. Provider will also comply with the terms of Plan’s FWA policies and procedures as set forth in the Provider Manual. [42 C.F.R. §422.503(b)(vii)(C)]
Compliance Program and Anti-Fraud Initiatives. The ACO shall develop and maintain an effective compliance program to detect, correct and prevent incidences of non-compliance with Applicable Requirements and incidences of fraud, waste and abuse relating to the MSSP and the federal healthcare program generally. The Participant shall comply with all requirements of the ACO’s compliance program. The ACO’s compliance program shall be appropriate to the ACO’s operations, shall be in compliance with, and be updated periodically to reflect changes in, law and regulations, and shall include at least the following elements:
a. a designated compliance official or individual who is not legal counsel to the ACO and reports directly to the ACO’s governing body;
b. mechanisms for identifying and addressing compliance problems related to the ACO’s operations and performance;
c. a method for the Participating Providers and other Network suppliers and providers to anonymously report suspected problems related to the ACO to the compliance officer;
d. compliance training for the Participating Providers and other Network suppliers and providers; and
e. a requirement that the ACO or the Participant report probable violations of law to an appropriate law enforcement agency.
