Managed Care

Compliance Program Self Assessment - CMS

  • 1.  Compliance Program Self Assessment - CMS

    Posted 09-12-2014 05:59 PM
    This message has been cross posted to the following eGroups: Managed Care and Chief Compliance and Ethics Officer Health Care .
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    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.

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    Philip Nieri
    VP Compliance
    Health Choice Management Co.
    Phoenix,AZ
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    2019 HCCA Compliance Institute


  • 2.  RE: Compliance Program Self Assessment - CMS

    Posted 09-12-2014 06:23 PM
    We post our P&P on the company's share drive and have employees sign an attestation upon initial hire and annually thereafter (when they complete their compliance training) that they have reviewed the Standard of Conduct/P&P. If we have any mid-year changes, we distribute/email the department heads and have them confirm when their employees have reviewed the updates. We were audited by CMS in 2012 and this element passed as long as we were able to prove that the employees had signed the attestation.

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    Annie Shieh Esq.,JD
    Senior Compliance Counsel
    Central Health Plan of California
    Diamond Bar,CA
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    2019 HCCA Compliance Institute