print page email page Home Delegated Vendor Compliance Attestation Delegated Vendor Compliance Attestation *Indicates required field. CMS and DHS require 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 compliance program requirements. By completing the following attestation, you certify that your organization is committed to fulfilling Medicare, Medicaid and/or CHIP Compliance Program requirements and any Compliance Program Requirements implemented by Health Partners Plans. For existing HPP Delegated Vendors, this attestation must be submitted back to HPP within 30 days of notification. Lines of Business (Select all HPP lines of business that your organization performs services for.) Medicare Medicaid CHIP 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 2023. 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 2023 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 2023 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 2023, 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 2023, 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 Delegated Vendor Information webpage. Medicaid and/or CHIP Fraud, Waste and Abuse (FWA) Education My organization ensured our HPP Medicaid and/or CHIP personnel received FWA education that included detailed information about: Federal and State laws regarding false claims, provider prohibited acts, civil or criminal penalties for false claims and statements, and whistleblower protections (including Section 6032 (A) of the Deficit Reduction Act (DRA), 42 U.S.C. § 1396a(a)(68), 62 P.S. §§ 1407 and 1408, and 43 P.S. §§ 1421-1428) and; methods to detect and prevent fraud, waste and abuse. This requirement was fulfilled in 2023 in the following ways: (Select 1 option that best describes your organization’s actions or enter an explanation in the comment box.) HPP’s Compliance Program and Code of Business Conduct documents were distributed to my organization’s HPP Medicaid and/or CHIP personnel (i.e., within 90 days of hire/contracting, when there are updates/revisions, and annually thereafter). My organization’s HPP Medicaid and/or CHIP personnel completed HPP’s Medicaid and CHIP FWA training module. My organization received HPP’s written FWA policies. We distributed our own similar policies to our Medicaid and/or CHIP personnel which included detailed information about Federal and State laws regarding false claims, provider prohibited acts, civil or criminal penalties for false claims and statements, and whistleblower protections (including Section 6032 (A) of the Deficit Reduction Act (DRA), 42 U.S.C. § 1396a(a)(68), 62 P.S. §§ 1407 and 1408, and 43 P.S. §§ 1421-1428) and methods to detect and prevent fraud, waste and abuse. My organization received HPP’s written FWA policies. Our Medicaid and/or CHIP personnel completed my organization’s FWA training curriculum which included detailed information about Federal and State laws regarding false claims, provider prohibited acts, civil or criminal penalties for false claims and statements, and whistleblower protections (including Section 6032 (A) of the Deficit Reduction Act (DRA), 42 U.S.C. § 1396a(a)(68), 62 P.S. §§ 1407 and 1408, and 43 P.S. §§ 1421-1428) and methods to detect and prevent fraud, waste and abuse. If the language stated above does not align with the actions of your organization, please explain below: Medicare Only Downstream Entity Status Please indicate if your organization contracted with downstream entities during 2023 to perform HPP related services: Yes, my organization contracted with downstream entities to perform HPP-related services in 2023. No, my organization did not contract with downstream entities to perform HPP-related services in 2023. Organizations with Downstream Entities in 2023 My organization conducted the following actions in 2023 to ensure its downstream entities were aware of and complied with the compliance requirements communicated in HPP’s COBC and Compliance Program Policy: (Select 1 option that best describes your organization’s actions or enter an explanation in the comment box.): My organization provided HPP's COBC and Compliance Policies to our downstream entities within 90 days of hire or contracting, upon revision, and annually thereafter. My organization provided our organization's own COBC and Compliance Policies, materially similar to HPP’s COBC and Compliance Policy, to our Downstream Entities within 90 days of hire or contracting, upon revision, and annually thereafter. Our downstream entities have been contractually required to have and distribute their own COBC and Compliance Policies. My organization conducts a review of our downstream entities’ COBC and Compliance Policies to ensure the content is sufficient. If your organization either does not comply with CMS’ COBC & Compliance Policies distribution requirements or satisfies the requirements via a different method not listed above, please explain below. (Select the option below or enter an explanation in the comment box.) In 2023, 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 its downstream entities, please explain below: 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. Organization Name* Organization Address, Line 1* Line 2 City* State* (please select) Alabama Alaska Arizona Arkansas California Colorado Connecticut Delaware Florida Georgia Hawaii Idaho Illinois Indiana Iowa Kansas Kentucky Louisiana Maine Maryland Massachusetts Michigan Minnesota Mississippi Missouri Montana Nebraska Nevada New Hampshire New Jersey New Mexico New York North Carolina North Dakota Ohio Oklahoma Oregon Pennsylvania Rhode Island South Carolina South Dakota Tennessee Texas Utah Vermont Virginia Washington West Virginia Wisconsin Wyoming Zip Code* Organization's Authorized Representative* Organization's Authorized Representative's Title* Organization's Authorized Representative Phone Number* Organization's Authorized Representative Email Address* Please direct questions or concerns regarding this attestation to MedicareFDR@hpplans.com.
