Important Medicare and Medicaid Compliance Requirement

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1.   All employees who provide services on behalf of VillageCareMAX’s Medicare or Medicaid plans, have within 90 days of hire and annually thereafter. This information is disseminated to employees and contractors upon hire and annually thereafter. A record of all employees and contractors receipt of the policies, Standards of Conduct, and information is maintained for a period of ten years and can be provided upon request.

 Completed Compliance and Fraud Waste and Abuse (FWA) training that meets the requirements outlined in Chapter 21 of the Medicare Managed Care manual and at a minimum:

• Code of Ethics/Standards of Conduct
• A method for reporting Compliance concerns
• A statement that good faith reporting shall carry no retaliatory actions

 My organization maintains a confidential FWA and Compliance reporting mechanism. It has been distributed and widely publicized for all employees and contractors within the organization to encourage reporting potential FWA and Compliance issues.

• The compliance policies and/or Standards of Conduct reflect a commitment to preventing, detecting, and correcting non-compliance.
• The compliance reference material includes, at minimum, laws and regulations related to MA and Part D FWA (i.e., False Claims Act, Anti-Kickback statute, HIPAA/HITECH, etc.);

*Note: Medicare has developed training to meet the annual training requirements. This training can be found on the Medicare Learning Network Provider (MLN) Compliance page as follows: http://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/ProviderCompliance.html

 Our organization reviews the Office of Inspector General (OIG) and General Service Administration (GSA) exclusion lists upon initial hire and monthly thereafter to ensure employees responsible for administering or delivering any Medicare or Medicaid benefits are not excluded from Federal Health Care Programs. If an employee is on either list that employee will immediately be removed from all work that directly or indirectly affects VillageCareMax’s Medicare and/or Medicaid plans.

 Our organization will comply with all applicable CMS guidance, HPMS memos and other reference materials during the term of the agreement with VillageCareMAX and will immediately notify VillageCareMAX of all suspected concerns of Medicare and/or Medicaid noncompliance or Fraud Waste & Abuse.

2.   Our organization will comply with requests from VillageCareMAX to validate that the representations made in this attestation are accurate including but not limited to:

• Providing copies of training materials and/or transcripts
• Code of Ethics/Standards of Conduct
• Provide documentation of the OIG GSA exclusion review
• Compliance Program policies and procedures

3.   Our organization will obtain attestations and/or other evidence of training from our sub-contracted or downstream entities with which we have contracted with and will upon request obtain the same documentation listed above for those entities.

*Important Reminder: VillageCareMAX’s Compliance Policy & Code of Conduct can be reviewed here: http://villagecare.org/compliance

I hereby attest that the information contained herein is accurate and complete.

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*Note: Although providers who are contracted with Medicare may be deemed as having met the FWA training requirement, they are not exempted from the annual Compliance training.