We are reviewing the compliance program effectiveness self assessment questionnaire that CMS posted earlier this year for Medicare Advantage Organizations. Element 1/Standard 3 assess whether the organization distributes its standards of conduct and P/Ps to its employees within 90 days of hire, when there are updates updates and annually thereafter. For the P/Ps portion of the standard, we provide training for new hires which contains information about and specific references to several compliance and fraud, waste and abuse policies. However, in lieu of providing a hard copy binder or zip file of all the Company's P/Ps, we point these new hires to our repository of policies and procedures across of lines of business and send periodic reminders about their availability and anytime there is a material change to them. Is this consistent with how other organizations meet this standard? Thank you.