Compliance and Fraud, Waste, and Abuse Programs
The Commonwealth Care Alliance Compliance Program
Commonwealth Care Alliance, Inc. (CCA), is committed to conducting its business operations in compliance with ethical standards, internal policies and procedures, contractual obligations, and all applicable federal and state statutes, regulations, and rules, including but not limited to those pertaining to the Centers for Medicare & Medicaid Services (CMS) Part C and D programs and the Massachusetts Executive Office of Health and Human Services (EOHHS), including MassHealth and the Office of Inspector General (OIG).
This Compliance Program applies to all lines of business at CCA. CCA’s compliance commitment includes its internal business operations, as well as its oversight and monitoring responsibilities related to its First Tier, Downstream, and Related Entities (FDR).
CCA has formalized its compliance activities through a comprehensive Compliance Program. The Compliance Program incorporates the fundamental elements of an effective compliance program identified by CFR 422.503(b) (4) (vi) and CFR 423.504(b) (4) (vi) and the OIG Federal Sentencing Guidelines.
Please view the Compliance Program document for more information.
The Commonwealth Care Alliance Fraud, Waste, and Abuse Program
The mission of the CCA Fraud, Waste, and Abuse (FWA) Program is to assist in protecting the integrity of CCA and federal and state programs by working to prevent, identify, investigate, correct, and report suspected incidents of fraud, waste, and abuse. Please view Attachment A: Glossary in the Compliance Program description for the definitions of fraud, waste, and abuse.
This FWA Program is an integral part of our Compliance Program. CCA must work collaboratively to combat fraud, waste, and abuse. Anyone conducting business with CCA is expected to report any suspected cases of fraud, waste, or abuse to CCA through one of the following reporting mechanisms without fear of retaliation or retribution for reports made in good faith:
Contact the Interim Chief Compliance Officer at CCA:
Elizabeth (Steffen) West
617-426-0600 Ext. 52376
30 Winter Street
Boston, MA 02108
Report to the CCA Compliance Hotline
Fill out a Compliance Incident Report
Compliance Incident Report1
CCA is subject to several laws and regulations pertaining to FWA, including, but not limited to, the federal Anti-Kickback Statute, the federal False Claims Act, the Massachusetts False Claims Law, and federal and state whistleblower protections. Please view Attachment A: Glossary in the Compliance Program description for the definitions of the anti-kickback statute and the Federal False Claims Act.
Using the Massachusetts False Claims law, the False Claims Division conducts civil investigations and prosecutions against companies and individuals who mislead or defraud state or municipal entities through the use of false or fraudulent claims, records, or statements. A whistleblower is a person who exposes any kind of information or activity that is deemed illegal, unethical, or not correct within an organization that is either private or public. Whistleblower laws protect those who report false or fraudulent activity against retaliation and are granted Federal and State Protection.
- Whistleblower / Fraud, Waste, and Abuse Information, Commonwealth of Massachusetts1
- The Whistleblower Protection Program1
Compliance and Fraud, Waste, and Abuse Program Resources
The Code of Conduct is the fundamental statement of the CCA governing principles. The Code of Conduct communicates to the Commonwealth Care Alliance workforce, providers, contractors, and First Tier, Downstream, and Related Entities (FDR) that compliance and ethics are an integral part of CCA. All FDRs must also distribute a Code of Conduct (Standards of Conduct) to their employees and downstream entities at time of hire/contract and annually thereafter. If an FDR does not have their own Code of Conduct, they may adopt the CCA Code of Conduct Fraud, Waste & Abuse Program Resources.
Visit the Medicare Learning Network1 for all CMS-sponsored training for providers and FDRs.
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