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If you have any questions regarding the information in CCA’s provider manual, please email Provider Relations at [email protected].

Section 16: Compliance and Fraud, Waste & Abuse Programs

Commonwealth Care Alliance’s 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 and Medicaid Services (CMS) Part C and D programs; the Massachusetts Executive Office of Health and Human Services (EOHHS), (MassHealth) and the Office of Inspector General (OIG). This Compliance Program applies to all CCA’s lines of business. 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.

CCA’s Compliance Program contains the following core elements including fraud, waste and abuse (FWA):

  • Code of Conduct and written Policies and Procedures
  • Compliance Officer, Compliance Committee and appropriate Oversight
  • Compliance Training and Education Program
  • Effective Lines of Communication and Reporting
  • Well-Publicized Disciplinary Standards and Enforcement
  • Effective System for Routine Monitoring, Auditing and Identification of Compliance Risks
  • Procedures for Prompt Response to Compliance Issues and Remediation
  • First Tier, Downstream and Related Entity Compliance Oversight

CCA’s Compliance Program is developed to:

  • Promote compliance with all applicable federal and state laws and contractual obligations;
  • Prevent, detect, investigate, mitigate and appropriately report suspected incidents of program non-compliance;
  • Prevent, detect, investigate, mitigate and appropriately report suspected incidents of fraud, waste and abuse;  and
  • Promote and enforce CCA’s Code of Conduct.