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Aaurlu Northweat Health
<br />Medicare Provider Compllance Addendum
<br />This ,fs ·a Medica re Provtder Compliance Addend~ITJ Uhe 'Compliance Aodendum') to the Participating
<br />Agreements and any and all amendments, addenda, aUachments or exhibits thereto (coUectively , the
<br />'Agreem11nt8" and each lndlvidually, the "Agreement'), between ~uris NorthWe!II Health ('Asuris") and (the
<br />"Prov ider" or 'FDR" as lhose terms are depned beloW), effec:tive th is First day ot October, 2016.
<br />WHEREAS, Asuris has contracts to administer Medicare Advantage Plans and/or Medicare Part D plans
<br />(collectively "Medicare') for the Centers for Medicare & Medicaid Services ('CMS') of the U.S. Department of
<br />Health and Human Services ("HHS') to administer Medicare benefits within certain counties;
<br />WHEREAS , the first lier, downstream or related entity ("FOR") has entered into an Agreement to provide
<br />heaflhcare and or administrative services relatei;t to Asurts'& Medfcare business; and
<br />WHEREAS, CMS requires Asurls to incorporate additional Medicare Compliance contrad language into its
<br />agreements with first tier, downstream, and related entities.
<br />NOW, THEREFORE, in consideration, and with full understanding that these provisions may be outlined in
<br />the main Agreement or addendum, the parties agree and will abide by the Compliance Addendum, as follows:
<br />1. Compliance w u, Mecfica(!]J,.a ~s~.Bs9J,!.!.rul..~..s!lli!...Q.M§..§!!!if.M2!!: FDR agrees to comply with all
<br />applicable Medicare laws, regulations, and CMS guidance. 42 C.F.R §§422.5040)(4}(v) and
<br />423.S0S(i)(4)(iv).
<br />2. Mm!i~J'.~~ndards !lllirul.Y.<J.Lll!!d Policies and Prqcedur~!.!; FOR agrees to meke available
<br />Standards of Conduct and policies and procedures to all of its employees who provide admlnlstralive
<br />services or heahh care services fQr Asuris's Medicare business pursuant to this Agreement at the
<br />lime of hire and annuaHy thereafter. FDR may either provide (a) Asuris's standards of Conduct and
<br />policies and procedures to FDR's employees, or (b) FDR's own comparable Standards of Conduct
<br />and policies and procedures to FDR 's emp loyees. Medicare Managed Care Manual ('MMC Manual"),
<br />Chapter 21, §§ 50.1.3 and 50.3.1; and Medicare Presaiption Drug Benefit Manual ('PDB Manual"),
<br />Chapter 9, §§ 50.1.3 and 50.3.1.
<br />3. Conlljct of lnteres1: POR agrees to comply with Aaurls!s Conflict of Interest Poli<.-y or its own Connie!
<br />of tn1erest Policy that complies with CMS requirements . FOR will requltu_ 11!1 governing body, officera,
<br />and senior leadership (as applicable) to sign a connlcl of interest at the t me of hire and annually
<br />thereafter certifying lhal they are free from an1 conmct of interellt related to Medicare. 42 C.F.R. §§
<br />422 .503(b)(4)(vl)(A) and 423.504(b)(4)(Vl)(A).
<br />4. r ~ and CFWA•l and General ~,:ig: FOR agrees that all of its
<br />e1r1ptoyees who provide actmlntS1taUve services or health care seNlces for Asurls's Medicare
<br />bualne89 pursuant to the Agreement participate In Meclicar11 Parts ,C end D FWMreining and
<br />Medicare Parts C and D General Compliance training with in ninety (90) days or hire and annually
<br />thereafter. Required FWA and General Compliance training Is developed and provided by CMS and
<br />Is available through the CMS Medicare Learning Network (MLN) at
<br />hit :/NNJW. !llJ.,99v/MLNProd1Jcl.§. FDRs who have met the FWA certification requirements through
<br />enrollment into the Medicare program or acc:redltatlon as a Durable Medical Equipment, Prosthetics,
<br />Orthottcs, and Supplies (DMEPOS) are deemed lo have met the training and educational
<br />requirements for fraud, waste . and abuse only . FDR must main fain documentation sufficient to
<br />demonstrate to AsUrts that FDR fulfilled the FWA end General Compliance training requirement.
<br />MMC Ma,iual, Chapter 21, § 50,3.2; PDB Manual , Chapter 9, § 50.3.2; 42 C .F.R. §§
<br />422.503(b)(4)(vi)(A) & (C) and 422.504(b)(4)(\tl)'(A) & {F).
<br />5. RAAQL\inQ.l&mrulance and FWA Conce rns: FDR agrees to report compliance or FWA concerns lo
<br />CMS or Asuils. Reporting shouJd occur within five (5) days of discovery ; If there Is an lmmedfate
<br />Impact to beneficiary access to care and/or a financlal strain , please report lmmedi.ately but al least
<br />wllhin twe,,ty-four (24) hours. Asurls has-a no-tolerance policy ror ~tallaUon or retribution against any
<br />employee or FDR for g(!Od-fa ilh reporting of FWA. 42 C.F.R. §§ 4-22 .503(b)(4)(vt)(O) -and
<br />423.504(b)(4)(vl)(O),
<br />AsurJa MA CompHance Addendum 1012015 A18816864AA Page 1 or 3
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