Common use of Compliance Program and Anti-Fraud Initiatives Clause in Contracts

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. Participant shall (Provider 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 Direct Contracting Model and the federal healthcare program generally. Such compliance program shall be appropriate to ParticipantProvider’s, Practice Providers’, or Supplier’s organization 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 from CMS.

Compliance Program and Anti-Fraud Initiatives. Participant shall (Provider 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 Direct Contracting Model and the federal healthcare program generally. Such compliance program shall be appropriate to ParticipantProvider’s, Practice Providers’, or Supplier’s organization organization, and operations and shall include:: NOT FOR EXECUTION 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 from CMS.

Compliance Program and Anti-Fraud Initiatives. Participant Provider 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 ParticipantProvider, 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