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Newly Delegated Vendor Compliance Attestation

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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.

This attestation is for newly contracted Delegated Vendors only. Please submit within 90 days of contracting.
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. We will provide HPP’s COBC/Compliance Program Policies to all 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 will be provided to allour employees within 90 days of hire, upon revision, and 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.)
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 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.)
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
My organization and/or any of our downstream/related entities
DO NOT engage in offshore operations for any administrative or healthcare services related to HPP business.
Do engage in offshore operations for any administrative or healthcare services related to HPP business.

If your organization and/or any of its downstream/related entities plan to engage in offshore operations related to HPP business, please obtain HPP approval prior to delegation. Once approval is received, complete the 'Offshore Subcontractor Attestation', located on the Delegated Vendor Information webpage, within 15 days of contracting

Medicaid and/or CHIP Fraud, Waste and Abuse (FWA) Education
My organization ensures our HPP Medicaid and/or CHIP personnel receive FWA education that includes 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.
We fulfill this requirement 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 received HPP’s written FWA policies (provided in HPP’s Compliance Program and Code of Business Conduct). We distribute 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 (provided in HPP’s Compliance Program and Code of Business Conduct). 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 contracts with downstream entities to perform HPP related services:
Yes, my organization contracts with downstream entities to perform HPP-related services.
No, my organization does not contract with downstream entities to perform HPP-related services.
Organizations with Downstream Entities
My organization will conduct the following actions to ensure its downstream entities are aware of and comply 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 are 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.
Downstream Entity Oversight (only applicable to First Tiers that subcontract delegated functions to another organization):
(Select the option below or enter an explanation in the comment box.)
We ensure compliance is maintained by our organization, perform ongoing oversight of our downstream entities and will disclose 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.