Thank you for your partnership with Health Partners Plans (HPP).

HPP is committed to fulfilling all Federal and State Compliance Program Requirements related our Medicare Advantage, Medicaid and CHIP products and is required to ensure our contracted partners, also referred to as delegated vendors, fulfill the compliance requirements related to the services they provide.

Please review all content on this webpage to ensure your organization understands and fulfill HPP Compliance Program Requirements.

General Compliance Program and Fraud, Waste and Abuse (FWA) Requirements

HPP requires its Delegated Vendors to fulfill the General Compliance Program and FWA Requirements listed below which are monitored through our Delegated Vendor Compliance Attestation processes (see section 2 for Compliance Attestation submission requirements).

Additional details for these requirements are provided in HPP’s Delegated Vendor Compliance Guide.

1. Code of Business Conduct (COBC)/Compliance Policies and Procedures Distribution (Applies to all HPP Delegated Vendors- Medicare First Tiers, Medicaid and CHIP Subcontractors)

Your organization is required to comply with and distribute HPP’s Code of Business Conduct and Compliance Program documents provided below or its own materially similar versions to all personnel assigned to perform HPP services within 90 days of contracting, annually thereafter and upon revision.

HPP Code of Business Conduct (COBC) (PDF)

HPP Compliance Program (PDF)

Medicare Downstream Entity Code of Business Conduct (COBC)/Compliance Policies and Procedures (Applies to Medicare only)

If your organization contracts with downstream entities to perform HPP Medicare Part C or D services, your organization must:

• Provide HPP's COBC and Compliance Program documents or its own similar versions to its downstream entities within 90 days of hire or contracting, upon revision, and annually thereafter; or
• Contractually require your downstream entities to have and distribute their own COBC and Compliance Policies and conduct a review of their COBC and Compliance Policies to ensure the content is sufficient.
• Monitor and audit your downstream entities’ performance to ensure compliance with all applicable CMS requirements and the requirements discussed in this Compliance Guide, HPP’s Code of Business Conduct and Compliance Program document.

2. Compliance Attestation and Other Form Requirements

There are certain Compliance Attestations and Forms HPP requires our Delegated Vendors to submit to help HPP monitor their fulfillment of General Compliance and FWA requirements related to our Medicare, Medicaid and CHIP programs.

Please see the table below for the links to the required attestations and forms your organization must submit along with due date timeframes and requirement applicability based on Program and Delegated Vendor types.

Form Link	Medicaid Subcontractors	CHIP Subcontractors	Medicare First Tier Entities	Due Date Timeframe
Newly Contracted Delegated Vendor Compliance Attestation	Required	Required	Required	Within 90 days of contracting with HPP
Annual Delegated Vendor Compliance Attestation	Required	Required	Required	Within 30 days of HPP notification
Offshore Subcontractor	Required	Required	Required	Within 15 days after Offshore contract signing *Note: HPP approval for Offshore Subcontracting is required prior to your offshore contract signing. Please obtain approval from HPP prior to submitting this form.
Downstream Entity	Not Applicable	Not Applicable	Required for HPP Medicare First Tier Entities that are not HPP Medicare Network Providers Only.	Submit within 90 days of contracting with HPP and when your organization contracts with new downstreams post HPP contracting.
Provider Compliance Attestation	Not Applicable	Not Applicable	Required for HPP Medicare Network Providers Only	Within 30 days of HPP notification

3. Reporting non-compliance and FWA Issues

Please ensure all personnel assigned to perform HPP services within your organization and its downstreams (when applicable) know the reporting mechanisms that are available to report non-compliance and FWA issues internally.

Your HPP assigned personnel should know:

• Their managers and/or direct reports are available to apply their business experience and help with making the right decisions.
• How to contact your organization's compliance department or general counsel.
• How to use other reporting methods made available by your organization.

Your organization must also have processes to report non-compliance and FWA issues that impact HPP business to HPP.  

Various mechanisms are in place for reporting concerns directly to HPP, such as:

• File a report through www.healthpartnersplans.com/report-compliance-issue. Reports filed through this webpage will be handled by a third-party vendor on behalf of HPP. An option for anonymous reporting is provided on the webpage.
• Call the Compliance Hotline - 1-866-477-4848. The hotline is answered by a third-party vendor on behalf of HPP, and is available 24/7. Although you may identify yourself within your report, you will also be afforded the right to remain anonymous. At the end of your report, you will be provided with an ID number that you may also use to call back and receive updates on any investigations.
• Email compliance concerns to compliance@hpplans.com.
• Email suspected or actual fraud, waste and abuse concerns to SIUtips@hpplans.com.
• HIPAA Privacy and Security Complaints can be sent directly to the Privacy Office by emailing PrivacyOfficial@hpplans.com

Additional Information

• The HPP Reporting Mechanisms listed above are also provided in HPP’s Code of Business Conduct and Compliance Program Documents.
• HPP Reporting Posters:
  • Reporting Concerns of Actual or Suspected Non-Compliance
  • Reporting Concerns of Actual or Suspected Fraud, Waste, or Abuse
4. Offshore Subcontracting Reporting

If your organization, its downstream or related entities plan to delegate any HPP Medicare, Medicaid or CHIP related work to an offshore subcontractor, approval from an authorized HPP representative must be obtained prior to delegation.

HPP’s Offshore Subcontractor form/attestation must be submitted within 15 calendar days from the offshore contract signing.

5. Employee Screening Requirements:

Your organization must ensure that its HPP assigned/contracted personnel, downstream entities and downstream entity personnel do not appear on any of the Federal and/or State exclusion lists shown on the table below. These screenings must be performed prior to hiring or contracting and monthly thereafter.

Exclusion Screening Requirements by Program
Exclusion List	Medicare	Medicaid and CHIP
OIG Excluded List- Department of Health and Human Services (DHHS) Office of Inspector General (OIG) List of Excluded Individuals and Entities	Pre-hire/contracting & Monthly	Pre-hire/contracting & Monthly
SAM Excluded List General Service Administration System for Award Management (SAM)	Pre-hire/contracting & Monthly	Pre-hire/contracting & Monthly
PA Medicheck (State Exclusion List- required for Medicaid and CHIP personnel only.)	Not Applicable	Pre-hire/contracting & Monthly

6. Medicaid/CHIP FWA Education Requirements

HPP is required to provide our Medicaid and CHIP Delegated Vendors with our written FWA policies to educate them and their HPP Medicaid and CHIP personnel about Healthcare FWA laws including:

• Federal and State laws regarding false claims, provider prohibited acts, civil or criminal penalties for false claims and statements, and whistleblower protections (including Section 6032 (A) of the Deficit Reduction Act (DRA), 42 U.S.C. § 1396a(a)(68), 62 P.S. §§ 1407 and 1408, and 43 P.S. §§ 1421-1428) and;
• methods to detect, prevent and report FWA.

This information is provided in HPP’s Code of Business Conduct (COBC) and Compliance Program Documents, located in section 1 of this webpage.

To ensure your organization fulfills Medicaid and/or CHIP FWA Education requirements, it must take one or more of the following actions:

• Comply with and distribute HPP’s Compliance Program Document and Code of Business Conduct documents to all personnel performing HPP Medicaid and/or CHIP services. To meet this requirement, distribution of paper copies is not required, however, your personnel must be made aware of these documents and their location; or
• Receive and comply with HPP FWA policies contained in our Compliance Program Document and Code of Business Conduct documents and provide your own similar FWA policies and procedures (P&Ps) and/or training to your HPP Medicaid and/or CHIP assigned personnel. If your organization chooses this second option, your FWA P&Ps and/or training content must include detailed information about Healthcare FWA laws including Federal and State laws regarding false claims, provider prohibited acts, civil or criminal penalties for false claims and statements, and whistleblower protections (including Section 6032 (A) of the Deficit Reduction Act (DRA), 42 U.S.C. § 1396a(a)(68), 62 P.S. §§ 1407 and 1408, and 43 P.S. §§ 1421-1428) and methods to detect, prevent and report fraud, waste and abuse.

Additional Resources for FWA Education content: Medical Assistance Bulletin 99-07-13

Inquiries

If you have questions regarding the Delegated Vendor information provided on this webpage, please feel free to contact your appropriate HPP representative or email MedicareFDR@hpplans.com.