• Distribute Independent Care Health Plan’s Compliance Program Materials (Code of Conduct and policies) or your own comparable materials to all employees and subcontractors providing services related to your iCare contract within 90 days of hire and annually thereafter.
• Provide Fraud, Waste, and Abuse training or your own comparable training to all employees and subcontractors providing services related to your iCare contract within 90 days of hire and annually thereafter (unless deemed)
• Screen all employees and subcontractors against the OIG and GSA exclusions databases.
• Receive an attestation from any subcontractors performing services related to your iCare contract that they have met these requirements.
• Retain all materials and documentation related to these compliance program requirements for 10 years.
• Sign and submit your FDR Compliance Attestations to Independent Care Health Plan, if requested

Please see below for additional details on FDR compliance program requirements and resources.

• Distribute compliance policies and procedures and standards of conduct to all employees and applicable subcontractors within 90 days of hire and annually thereafter
• Provide Fraud, Waste, and Abuse training meeting CMS requirements to all employees and applicable subcontractors within 90 days of hire and annually thereafter, unless deemed (see additional details below)
• Screen all employees (permanent/temporary/intern) and subcontractors against the Office of the Inspector General (OIG) and General Services Administration (GSA) Exclusion Lists prior to hire and monthly thereafter
• Ensure any contracted entities performing delegated functions related to iCare’s Medicare contract comply with all requirements
• Retain materials and documentation related to compliance program requirements for 10 years

To help ensure we are all doing our part to prevent, detect, and correct FWA and Medicare noncompliance, and best serve our beneficiaries, all required materials are provided to you for use.

FDRs may also attest to meeting requirements using their own compliance materials, as long as they meet the CMS requirements and can be made available upon request for auditing and monitoring purposes.

To assist us in our required compliance program oversight, we ask you to complete an annual Medicare FDR Compliance Attestation and return it to us through one of the following methods:

• Email: compliance@icarehealthplan.org
• Fax: 414-231-1092
• Mail: Independent Care Health Plan
  • Attention: Compliance Dept./FDR Oversight
  • 1555 N. RiverCenter Drive, Suite 206
  • Milwaukee, WI 53212

Additional information regarding compliance program requirements and resources are outlined in the next section.

At minimum, policies and procedures and/or Standards of Conduct must accomplish the following:

• Articulate commitment to comply with all applicable Federal and State Standards
• Describe compliance expectations as embodied in the Standards of Conduct
• Provide guidance on dealing with suspected, detected, or reported compliance issues
• Identify how to communicate compliance issues to appropriate compliance personnel
• Describe how suspected, detected or reported compliance issues are investigated and resolved

As part of our efforts to improve the healthcare system, Independent Care Health Plan (iCare) has made a commitment to detecting, preventing and correcting Medicare fraud, waste and abuse (FWA). Success in this effort is essential to maintaining a healthcare system that is affordable for everyone. iCare continues to spread the word about how physicians, other healthcare professionals and third parties can help combat FWA.

CMS requires training upon employment or contract and annually thereafter on this topic for those rendering services or supporting those services for a Medicare-eligible beneficiary. iCare and our parent company, Humana, have integrated guidance on this topic in core Humana Compliance Program documents used by iCare:

• Compliance Policy for Contracted Healthcare Providers and Third Parties
• Ethics Every Day for Contracted Healthcare Providers and Third Parties

For purposes of the relationships that contracted healthcare professionals and third parties* have with iCare, FWA-related content within these documents, including all references and requirements related to Medicare Part C and Part D, applies to all iCare plans.

Organizations are responsible for developing training on this topic or using other FWA training. However, contracted healthcare professionals and third parties supporting iCare’s Medicare products may use content from or integrate the above-listed Humana documents in the FWA training they provide to their employees and those supporting their organization. This training allows these contracted healthcare professionals and third parties to meet their contractual obligation to iCare to train individuals on FWA:

*CMS designates these as first-tier, downstream and related entities (FDRs).

For additional information about FWA, please refer to the link below:

• What are Fraud, Waste and Abuse?

All employees, officers and directors, governing body members, subcontracts, consultants, and vendors as applicable, must be screened against both the OIG and GSA exclusions lists prior to hire or contracting and monthly thereafter. You must notify iCare immediately in the event an excluded individual or entity is identified. Excluded persons or entities are prohibited from receiving payment.

• OIG: https://oig.hhs.gov/
• GSA: https://www.sam.gov/SAM/

Records of exclusion screening should clearly identify the search name, date, database, and results.

If any functions related to services you provide applying to iCare’s Medicare contract are subcontracted to a downstream entity, you are obligated to ensure all CMS requirements are met. iCare also retains the right to conduct oversight activities.

Sponsors are accountable for maintaining compliance program records for a period of 10 years including time, attendance, topic, certificates of completion (if applicable), and test scores of any tests administered to their employees or contracted entities.

• The Medicare Learning Network: The Medicare Learning Network or (MLN) is the website for official CMS educational products, including free web-based training courses.
• The Office of the Inspector General’s Compliance Resource Portal: The OIG Compliance Resource Portal offers free educational materials, including videos, for all areas of healthcare compliance.

You can report concerns by:

Clicking: www.ethicshelpline.com

Emailing: siureferrals@humana.com

Calling: 1-877-5-THE-KEY (1-877-584-3539)

Phone: English 1-800-614-4126

Fax: 1-920-339-3613

Mailing: Humana, Special Investigation Unit, 1100 Employers Blvd., Green Bay, WI 54344

*Anonymous Reporting Option

iCare enforces a strict no-tolerance policy for intimidation, retaliation, or retribution against any reporter who in good faith reports suspected Fraud, Waste, or Abuse or suspected compliance concerns. Reporters are protected from retaliation for False Claims Act complaints, as well as any other applicable anti-retaliation protections.

In the event of a report, iCare will provide the reporter, if not reported anonymously, information regarding expectations of a timely response, confidentiality, non-retaliation and progress reports.