The Federal Medicare Shared Savings Program ("MSSP") regulations applicable to ACOs participating in the MSSP require such ACOs to have a compliance plan that, at a minimum, has five (5) specified elements. This ACO Compliance Plan outlines how INTEGRIS Health Partners ("the ACO") will satisfy these five required Plan elements. The entire Compliance Plan can be found here.A summary of the Compliance Plan is described below.
Element #1: ACO’s compliance official is Samuel Rogers, Chief Compliance Officer of INTEGRIS Health. The compliance official is not legal counsel to the ACO and reports directly to the ACO’s governing body.
Element #2: Mechanisms are in place for identifying and addressing compliance problems related to the ACO’s operations and performance, utilizing investigation guidelines, annual risk assessment, for-cause and not-for-clause audits. The ACO will identify, resolve, recover funds, report, and, when appropriate, take legal action if suspected fraud, waste, and/or abuse has occurred. Resolution of noncompliant activity may include termination of participation in the ACO. The ACO embraces a zero-tolerance policy against retaliation for good faith reporting of issues or concerns.
Element #3: The ACO uses multiple methods to assist caregivers and personnel in reporting suspected fraud, abuse, illegal activity, unethical conduct, policy violation, or other compliance concerns. Anonymous reporting can be made to the Compliance department through any of the following ways:
Element #4: Compliance Training: will be required and provided upon joining and annually thereafter. Topics covered include what constitutes program violations, how to identify program violations, examples of Fraud, Waste and Abuse, and how to report potential compliance issues or concerns.
Element #5: The ACO must report probable violations of law to an appropriate law enforcement agency. It is the role and responsibility of the ACO’s compliance official to report misconduct to CMS, its designee, and law enforcement as needed. If a compliance issue rises to the level of a potential violation of law, the compliance official will work in coordination with the ACO’s counsel to make that determination and, if necessary, to develop a reporting plan.
The ACO has adopted the INTEGRIS Health written Code of Ethical Business Conduct as part of the ACO’s Compliance Plan. All ACO Caregivers and ACO Personnel must comply with the Code of Ethical Business Conduct. ACO Caregivers and Personnel complete an acknowledgment within 30 days of employment or engagement that they have received, reviewed, and will abide by its content. The IH ACO Compliance Officer or a member of the Compliance Department will meet with anyone who refuses to sign the certification form to answer questions or concerns.
The ACO has written policies and procedures, which describe compliance expectation, implement the compliance program, provide compliance guidance to the ACO's Personnel and others, identify ways to communicate compliance issues, and describe how compliance issues are investigated and resolved.
