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.
Appears in 4 contracts
Samples: Aetna Better Health of Newjersey Medicaid Facility Services Agreement, Services Agreement, Group Agreement
