Medicare Compliance Program Requirements. Contractor shall implement a comprehensive Compliance Program for all activities, particularly those related to documentation, claims processing, billing and collection processes. Contractor’s Compliance Program shall substantially comply with the current regulatory approach program outlined in the Office of Inspector General (OIG) Compliance Program Guidance for Ambulance Suppliers as published in the Federal Register on March 24, 2003 (03 FR 14255).
Medicare Compliance Program Requirements. (a) Facility agrees to comply with all applicable requirements set forth in the CMS Compliance Program Guidelines (“Compliance Program Guidelines”) that apply to “first tier entities” and/or “downstream entities,” as those terms are defined by CMS. In accordance with the Compliance Program Guidelines, Company will provide to Facility general compliance information through distribution of Company’s standards of conduct and/or compliance policies and procedures (“Company Standards of Conduct”).
(b) Consistent with the Compliance Program Guidelines, Facility agrees to either: (1) distribute Company Standards of Conduct to Provider Related Parties, or (2) adopt standards of conduct and prepare compliance policies and procedures that are detailed and specific and describe the operation of Facility’s compliance program (“Provider Standards of Conduct”), and distribute such Provider Standards of Conduct to Provider Related Parties. Facility agrees that distribution of Company or Provider Standards of Conduct shall occur within ninety (90) days of hire or contracting, when there are updates to such Standards of Conduct, and annually thereafter. Further, Facility must maintain documentation necessary to demonstrate to Company and CMS that Company or Provider Standards of Conduct was distributed to Provider Related Parties as required in the Compliance Program Guidelines (“Standard of Conduct Documentation”). Facility agrees that Standard of Conduct Documentation is “Information and Records,” as defined in Section 5.3.2 of this Agreement, and will maintain and provide access to all Standard of Conduct Documentation as described in Section 5.3.2 of this Agreement.
(c) In accordance with the Compliance Program Guidelines, Facility shall ensure that all of Provider’s Related Parties complete a Medicare fraud, waste and abuse training course (“Medicare Compliance Training”). Provider Related Parties may complete Medicare Compliance Training by completing: (1) the CMS “Medicare Parts C&D Fraud, Waste and Abuse” course (“CMS Module”), which is available on CMS’ website, or (2) a course provided by Facility. Provider Related Parties meeting the CMS Medicare Compliance Training requirements through enrollment in the fee‐for‐service Medicare program or accreditation as a durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) provider are deemed by CMS rules to have met the Medicare Compliance Training requirement in this Section. Facility agrees that new Pr...
Medicare Compliance Program Requirements. Contractor shall implement a comprehensive Compliance Program for all activities, particularly those related to documentation, claims processing, billing, and collection processes. Contractor’s Compliance Program shall substantially comply with the current regulatory approach program outlined in the Office of Inspector General (OIG) Compliance Program Guidance for Ambulance Suppliers as published in the Federal Register on March 24, 2003 (03 FR 14255). In addition, on April 24, 2023, the OIG announced its plans to improve and update existing compliance program guidance documents (CPGs). Contractor agrees to comply with any CPGs and supplemental CPGs for Ambulance Suppliers that OIG may issue after the start of this Agreement.
