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Existing FDR Compliance Attestation

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First Tier, Downstream and Related Entity (FDR) Compliance Attestation

CMS requires any organization or individual that contracts with Health Partners Plans (HPP) to provide administrative or healthcare service functions on HPP's behalf to comply with various CMS program requirements. By completing the following attestation, you certify that your organization is committed to ensuring compliance with HPP and CMS requirements. Additional information on the below requirements can be found on our website at:

https://medicare.healthpartnersplans.com/medicare-fdr-information

For existing HPP FDRs, this attestation must be submitted back to HPP no later than February 28 of every year.


Code of Business Conduct and Compliance Program Policy Distribution:

(Select 1 option that best describes your organization’s actions or enter an explanation in the comment box.)
HPP's Code of Business Conduct (COBC) and Compliance Program Policies were made available to our organization in 2020. We have provided HPP’s COBC/Compliance Program Policies to all of our employees initially within 90 days of hire or contracting, upon revision, and will continue to provide them annually thereafter.
My organization’s Code of Conduct and/or Compliance Program Policies are materially similar to HPP’s COBC and Compliance Program Policy content and were provided to all of our employees in 2020 within 90 days of hire and upon revision. We will continue to provide them annually thereafter.
If the organization does not adopt and comply with HPP's COBC and Compliance Policy, or a materially similar version, please explain below:


OIG/SAM/Medicheck Exclusion Screening:

(Select the option below or enter an explanation in the comment box.)
In 2020 my organization reviewed the OIG LEIE, SAM EPLS and Medicheck (applicable to work related to HPP's Medicaid/CHIP lines of business) prior to the hiring or contracting of all personnel involved in the administration or delivery of HPP benefits and monthly thereafter.
If the organization did not perform exclusion screenings as stated above, please explain below:


Reporting Mechanisms:

(Select the option below or enter an explanation in the comment box.)
In 2020, internal employees were informed of their obligation and how to report any suspected or detected non-compliance or potential FWA for internal investigation. The reporting mechanisms ensure confidentiality and allow for anonymity, as desired. In addition, we don't allow retaliation or intimidation against anyone who reports in good faith. In turn, our organization reports any applicable incidents to HPP as they arise.
If the language stated above does not align with the actions of your organization, please explain below:


Offshore Subcontractor Reporting

During 2020, my organization and/or any of our downstream/related entities (CHECK ONE) Did DID NOT engage in offshore operations for any administrative or healthcare services related to HPP business. If your organization and/or any of our downstream/related entities engaged in offshore operations related to HPP business, please complete the "Offshore Subcontractor Attestation" for each entity, located on the Medicare FDR Information webpage.



Communication of Compliance and Fraud, Waste and Abuse Requirements:

My organization ensured FWA and General Compliance requirements were communicated to our HPP Medicare FDR personnel during 2020 in the following ways (check all that apply).

My organization communicated FWA and General Compliance requirements to our employees via Code of Conduct and/or Compliance Program Policy and Procedure content and complied with the Code of Conduct/Compliance P&P distribution requirements (i.e., within 90 days of hire/contracting, when there are updates/revisions, and annually thereafter).
My organization included CMS FWA and General Compliance Training modules or CMS FWA and General Compliance Training content in our employee training curriculums. (Optional)
My organization utilized HPP’s FWA and General Compliance training resources. (Optional)
My organization provided our own FWA and General Compliance training to our employees. (Optional)
If the language stated above does not align with the actions of your organization, please explain below:


Downstream Entity Status

Please indicate if your organization contracted with downstream entities during 2020 to perform HPP related services:

Yes, my organization contracted with downstream entities to perform HPP-related services in 2020.
No, my organization did not contract with downstream entities to perform HPP-related services in 2020.




As an authorized representative for the organization named below, I certify that I have reviewed and understand all of the requirements within HPP's vendor policy, that the above statements are true to the best of my knowledge, and that my organization maintains records that support our compliance.


























Please direct questions or concerns regarding this attestation to MedicareFDR@hpplans.com.