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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 behalf of HPP 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.


Compliance Information:

HPP's Code of Conduct (COC) and Compliance Policies have been made available to our organization in 2019. We have provided HPP’s COC/Compliance 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 utilized our own comparable version of the Code of Conduct (COC) and Compliance Policies in 2019. The COC/Compliance Policies have been made available to all of our employees initially within 90 days of hire or contracting, upon revision, and will continue to provide them annually thereafter.
If the organization does not adopt and comply with HPP's COC and Compliance Policy, or a materially similar version, please provide an explanation below:


Compliance Information (applicable to organizations with Downstream Entities. If your organization does not have downstream entities, please check the "Not Applicable" box):

My organization ensured our downstream entities who are assigned to work on HPP's business during 2019 received HPP's COC/ Compliance Policies. We have provided HPP's COC/Compliance Policies to all of our downstream entities initially within 90 days of hire or contracting, upon revision, or to meet the annual distribution requirement.
My organization ensured our downstream entities (if applicable) who are assigned to work on HPP's business receive our organization's COC/Compliance Policies. In 2019, we provided our COC/Compliance Policies to all of our downstream entities initially within 90 days of hire or contracting, upon revision, or to meet the annual distribution requirement.
My organization ensured downstream entities have been contractually required to have such policies. If our downstreams utilize their own comparable versions, my organization conducts a review of those policies from a sample of downstream entities to ensure the content is sufficient.
Not Applicable.
If the organization does not ensure that your downstream entities adopts and comply with HPP's COC and Compliance Policy, or a materially similar version, please provide an explanation below:


OIG/SAM/Medicheck Exclusion Screening:

My organization attests that during 2019, we 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 on a monthly basis thereafter.
If the organization did not perform exclusion screenings as stated above, please provide an explanation below:


Reporting Mechanisms:

During 2019, 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 above stated language does not align with the actions of your organization, please provide an explanation below:


Offshore Subcontractor Reporting

During 2019, 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.



Downstream Entity Oversight (only applicable to First Tiers that subcontract delegated HPP functions to another organization):

My organization attests that during 2019 we ensured compliance was maintained by our organization, performed ongoing oversight of our downstream entities and disclosed issues identified to HPP as soon as possible.
If the organization did not perform ongoing oversight over the downstream entities, please provide an explanation below:


Communication of Compliance and Fraud, Waste and Abuse Requirements:

As of January 1, 2019, HPP ended the requirement that our Medicare FDR personnel who are involved in the administration or delivery of HPP Medicare benefits must complete FWA and General Compliance Training within 90 days of contracting/hiring and annually thereafter. Although completion of FWA and General Compliance training is not required, my organization ensured FWA and General Compliance requirements were communicated to our HPP Medicare FDR personnel during 2019 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 above stated language does not align with the actions of your organization, please provide an explanation below:

As authorized representative for the below named organization, 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.