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Offshore Subcontractor

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First Tier Contact Information

PART I. Offshore Subcontractor Information

PART II. Precautions for Protected Health Information (PHI)

Part I. Attestation of Safeguards to Protect Beneficiary Information in the Offshore Subcontract

Item Attestation Response
I.1. Offshore subcontracting arrangement has policies and procedures in place to ensure that Medicare beneficiary protected health information (PHI) and other personal information remains secure.*
I.2. Offshore subcontracting arrangement prohibits subcontractor's access to Medicare data not associated with the sponsor's contract with the offshore subcontractor.*
I.3. Offshore subcontracting arrangement has policies and procedures in place that allow for immediate termination of the subcontract upon discovery of a significant security breach.*
I.4. Offshore subcontracting arrangement includes all required Medicare Part C and D language (e.g., record retention requirements, compliance with all Medicare Part C and D requirements, etc.)*

Part II. Attestation of Audit Requirements to Ensure Protection of PHI

Item Attestation Response
II.1. Organization will conduct an annual audit of the offshore subcontractor.*
II.2. Audit results will be used by the Organization to evaluate the continuation of its relationship with the offshore subcontractor.*
II.3. Organization agrees to share offshore subcontractor's audit results with CMS, upon request.*

Please direct questions or concerns regarding this attestation to