The CCA Health Compliance Program
CCA Health 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 and Medicaid Services (CMS) Part C and D programs; the Michigan Department of Health and Human Services; and the Office of the Inspector General (OIG).
This Compliance Program applies to all lines of business at CCA Health. CCA Health’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 Health 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 CCA Health Fraud, Waste, and Abuse Program
The mission of the CCA Health Fraud, Waste, and Abuse (FWA) Program is to assist in protecting the integrity of CCA Health 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 Health must work collaboratively to combat fraud, waste, and abuse. Anyone conducting business with CCA Health is expected to report any suspected cases of fraud, waste, or abuse to CCA Health through one of the following reporting mechanisms without fear of retaliation or retribution for reports made in good faith:
Contact the chief compliance officer at CCA Health:
617-426-0600 Ext. 52376
30 Winter Street
Boston, MA 02108
Report to the CCA Health Compliance Hotline:
Fill out a compliance incident report:
Compliance Incident Report1
CCA Health 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, 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 Michigan False Claims Act, 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.
Compliance and Fraud, Waste, and Abuse Program Resources
The Code of Conduct is the fundamental statement of the CCA Health governing principles. The Code of Conduct communicates to the CCA Health workforce, providers, contractors, and FDRs that compliance and ethics are an integral part of CCA Health. 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 Health Code of Conduct Fraud, Waste & Abuse Program Resources.
Visit the Medicare Learning Network1 for all CMS-sponsored training for providers and FDRs.
Compliance Fraud and Abuse Training for First-Tier, Downstream, and Related Entities (FDRs)
CCA Health requires annual training to detect, prevent, and correct fraud, waste, and abuse. All providers and their employees, contractors, governing bodies and downstream entities who partner with Medicare Advantage and Part D prescription drug plans are required to take training that covers this topic.
Your applicable employees and downstream entities assigned to provide administrative healthcare services for CCA Health can access the training through the CMS Medicare Learning Network (MLN) at https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/WebBasedTraining.1 FWA training is called “Combating Medicare Parts C and D Fraud, Waste, & Abuse.”
Once completed, download and retain the certificate of completion. The certificates must be made available to CCA Health and/or CMS upon request. Records of the training, including participant names, must be retained and available for inspection upon request for 10 years after the end date of the provider’s contract with CCA Health.
Your organization can also download the materials and incorporate them into your internal training; however, you cannot change the content of the MLN training. If your organization decides to incorporate into your internal training, you must have a mechanism to track that the training was completed.
Providers who use their own training programs can incorporate the content from the Medicare Parts C and D, fraud, waste and abuse training1 and the Medicare Parts C and D general compliance training1 modules into their training materials.
Regardless of the option you choose, certificates of completion must be kept on file for 10 years, and the training must be completed:
- Within 90 days of initial hire or the effective date of contracting AND
- at least annually during each calendar year (January 1–December 31) thereafter
Who should take the training?
Not every employee needs to take training. Below are examples of critical roles within FDRs that clearly should be required to fulfill the training requirements:
- Senior administrators or managers directly responsible for the FDR’s contract with CCA Health
- Individuals involved with decision-making authority on behalf of CCA Health
- Reviewers of beneficiary claims and services submitted for payment
- Individuals or teams handling part of the Medicare or Medicaid benefit that CCA has subcontracted the FDR for
- Individuals with job functions that place the FDR in a position to commit significant noncompliance with CMS program requirements or healthcare FWA
The only exceptions to this training requirement are if you/your organization is deemed to have met the FWA certification requirements through enrollment into Medicare Part A or B of the Medicare program or though accreditation as a supplier of durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS); or your organization has, through vetting with the FDR team, provided a copy of your training materials to the CCA Compliance team for review. With their approval, if your training meets acceptable standards, you will be exempted provided your organization can provide routine monitoring on you being trained at hire and annually thereafter.
For the deeming as a Medicare Supplier, you can find the training requirements and information about deemed status in:
- 42 CFR § 422.503(b)(4)(vi)(C) for MA
- 42 CFR § 423.504(b)(4)(vi)(C) for Part D
- Medicare Managed Care Manual, Chapter 21 § 50.3
If you have any questions regarding these instructions, concerns about what and who to report information to regarding what is required in this document, please reach out to the CCA Health Compliance Hotline at 833-610-0005.
1 When you click this link, you will leave the CCA Health website.