Contracted Health Care Provider Compliance Attestation

The Centers for Medicare & Medicaid Services (CMS) requires any organization or individual that contracts with Health Partners Plans (HPP) to provide administrative or healthcare services to beneficiaries to 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 Providers, this attestation must be submitted back to HPP within 30 calendar days from the date of request.    For newly contracted providers, this attestation must be submitted back to HPP within 90 calendar days of contract execution.

Code of Conduct and Compliance Policies for Contracted Health Care Providers

HPP complies with CMS' distribution of the Code of Conduct (COC) and Compliance Policies requirements. HPP provides access to HPP's COC and Compliance Policy via the Provider Manual. Furthermore, HPP ensures the documents are readily available on HPP's Medicare FDR Webpage.

I hereby acknowledge and agree that my organization:

	Has been provided, read, understands and is compliant with the HPP's COC and Compliance Policy Either adopts and complies with HPP's COC and Compliance Policy or has its own policy that is materially similar to the HPP's COC & Compliance Policy and complies with that policy
	Accept - My organization adopts and complies with HPP's COC and Compliance Policy.
	Accept - My organization has adopted another policy that is materially similar to the HPP COC and Compliance Policy and complies with that policy.

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.

Fraud, Waste, and Abuse and General Compliance Training for the Organization's Employees:

HPP complies with CMS' training requirements. HPP provides access to the CMS Medicare Learning Network (MLN) Fraud, Waste, and Abuse (FWA) and General Compliance training content via inclusion of the content in HPP's Provider Manual. Furthermore, HPP provides a link to access the CMS Fraud, Waste, and Abuse and General Compliance Training on HPP's Medicare FDR Webpage.

The FWA and General Compliance trainings include CMS content that cannot be modified beyond the extent permissible.

I hereby acknowledge and agree that my organization:

Has been provided, read and understands the CMS Medicare Parts C and D FWA Training and General Compliance Training (CMS training); and Trains its employees using the CMS training.

Note: Utilizing the Organization's own version of FWA/ General Compliance training without inclusion of the CMS required content is considered to be non-compliant with regulatory requirements.

	Accept - My organization adopts and trains its employees using the CMS General Compliance and FWA trainings. My organization does not modify the content beyond the extent permissible. My organization is able to supply proof of training completion upon request.
	Accept - My organization has met the FWA certification requirements through enrollment into the Parts A or B of the Medicare program or accreditation as a Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS); therefore, my organization is considered deemed and exempt from completion of FWA training, but ensures general compliance training is provided to all employees and downstream entities who are assigned to work on HPP's Medicare line of business. The general compliance training complies with CMS requirements and includes the CMS General Compliance training content without modification beyond the extent permissible.

If the organization does not comply with the CMS FWA and General Compliance training requirements, please provide an explanation below.

Organizations with Downstream Entities (Only organizations with Downstream Entities should complete this section):

	Accept- My organization ensures our downstream entities (if applicable) who are assigned to work on HPP's business receive HPP's Provider Manual, which includes HPP's Code of Conduct (COC), Compliance Policies, and the CMS Medicare Learning Network (MLN) Fraud, Waste, and Abuse (FWA) and General Compliance training content. We have provided HPP's Provider Manual to all of our downstream entities initially within 90 days of hire or contracting, upon revision, and annually thereafter.
	Accept- My organization ensures our downstream entities (if applicable) who are assigned to work on HPP's business receive our organization's Provider Manual, which includes our Code of Conduct (COC), Compliance Policies, and the CMS Medicare Learning Network (MLN) Fraud, Waste, and Abuse (FWA) and General Compliance training content. We have provided our Provider Manual to all of our downstream entities initially within 90 days of hire or contracting, upon revision, and annually thereafter.
	Accept- My organization ensures our downstream entities (if applicable) who are assigned to work on HPP's business receive our organization's COC and Compliance Policies. We have provided our COC and Compliance Policies to all of our downstream entities initially within 90 days of hire or contracting, upon revision, and annually thereafter.
	Furthermore, we require that all downstream entities satisfy the CMS FWA and General Compliance training requirement via one of the following: Completing the CMS Medicare Learning Network (MLN) FWA training and General Compliance education modules, with certificates of completion available upon request Incorporating the content of the CMS standardized FWA and General Compliance training modules from the CMS website into their existing compliance training materials/systems. The CMS module content must not be modified beyond the modifications to the appearance of the content (i.e. font, color, background, format, etc.). The Downstream Entity is aware of the need to supply proof of training completion upon request. Incorporating the content of the CMS training module into written documents for providers (e.g. Provider Guides, Participation Manuals, and Business Associate Agreements, etc.).
	Accept- My organization ensures downstream entities have been contractually required to have and distribute their own COC and Compliance 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.
	Furthermore, we require that all downstream entities satisfy the CMS FWA and General Compliance training requirement via one of the following: Completing the CMS Medicare Learning Network (MLN) FWA training and General Compliance education modules, with certificates of completion available upon request Incorporating the content of the CMS standardized FWA and General Compliance training modules from the CMS website into their existing compliance training materials/systems. The CMS module content must not be modified beyond the modifications to the appearance of the content (i.e. font, color, background, format, etc.). The Downstream Entity is aware of the need to supply proof of training completion upon request. Incorporating the content of the CMS training module into written documents for providers (e.g. Provider Guides, Participation Manuals, and Business Associate Agreements, etc.).

If the Organization either does not comply with the CMS COC & Compliance Policies distribution requirements, the FWA and General Compliance training requirements, or satisfies all requirements via a different method not listed above, please provide an explanation below.

OIG/SAM Exclusion Screening:
	My organization attests that we review the OIG-LEIE and SAM-EPLS prior to the hiring or contracting of all personnel involved in the administration or delivery of HPP benefits and on a monthly basis thereafter.
Reporting Mechanisms:
	Employees and downstream entities (if applicable) 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.

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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.

Organization Name*

Organization Address, Line 1*

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Zip Code*

Tax ID Number*

Organization's Authorized Representative*

Organization's Authorized Representative's Title*

Organization's Authorized Representative Phone Number*

Organization's Authorized Representative Email Address*