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Newly Contracted 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 health care 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 newly contracted FDRs, this attestation must be submitted back to HPP within 90 days of contract.


Compliance Information:

My organization affirms that we have a Code of Conduct and Compliance Policies that communicate the organization's compliance expectations. We affirm that our COC and Compliance Policies are distributed to all the organization's employees. Distribution occurs within 90 days of hire/contracting, when there are updates/revisions, and annually thereafter.
My organization will utilize HPP's Code of Conduct (COC) and Compliance Policies that have been made available to the organization. We will provide HPP's COC/Compliance Policies to all our employees within 90 days of this contract execution, upon revision and annually thereafter. Distribution of HPP's COC/Compliance Policies to employees who are hired after this 90-day period will occur within 90 days of hire, upon revision and 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 will ensure that our downstream entities who are assigned to work on HPP's business receive (choose one):

My organization's Code of Conduct and Compliance Policies
My downstream entity(ies) may use their own comparable Code of Conduct and Compliance Policies. We ensure that it captures the downstream entity's intent to comply with federal regulations. In addition, my organization conducts reviews of those policies from a sample to ensure the content is sufficient.
My organization provides our downstream entities with a copy of HPP's Code of Conduct and Compliance Policies.
Not Applicable
If the organization does not perform ongoing oversight over the downstream entities, please provide an explanation below:


OIG/SAM/Medicheck Exclusion Screening:

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


Reporting Mechanisms:

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:

My organization and/or any of our downstream/related entities (CHECK ONE) DO DO NOT engage in offshore operations for any administrative or health care services related to HPP business. If yes, please complete the “Offshore Subcontractor Attestation” for each entity.


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

My organization attests that we will ensure compliance is maintained by our organization and perform ongoing oversight of our downstream entities and disclose issues identified to HPP as soon as possible.
If the organization does 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 no longer requires Medicare FDR personnel who are involved in the administration or delivery of HPP Medicare benefits to 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 will ensure FWA and General Compliance requirements are communicated to its HPP Medicare FDR personnel through one or more of the methods described below. Please check all ways that apply:

My organization will communicate FWA and General Compliance requirements to its employees via Code of Conduct and/or Compliance Program Policy and Procedure content and will comply 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).
CMS FWA and General Compliance Training modules or CMS FWA and General Compliance Training content will be included in my organization's employee training curriculums. (Optional)
My organization will utilize HPP's FWA and General Compliance training resources. (Optional)
My organization will provide its own FWA and General Compliance training to its employees. (Optional)
If the above stated language does not align with the actions of your organization, please provide an explanation below:


By completing this attestation your organization is acknowledging your intent to comply with HPP's vendor policy and with Federal and State requirements. Be advised that in the upcoming year, your organization will be required to affirm that the aforementioned vendor requirements were completed.


As an 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.