ACO Compliance Plan

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 Lea Fourkiller, 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.

Written Policies and Procedures

Code of Ethical Business Conduct

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.

Policies and Procedures

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.

  1. INTEGRIS Health Partners Medicare Shared Savings ACO Compliance Plan
  2. Distribution of Code of Ethical Business Conduct
  3. ACO Policy Manual Introduction, ACO-ADM-100
  4. ACO Policy Manual Glossary, ACO-ADM-100.1
  5. Record Retention and Access, ACO-ADM-101
  6. Communications and Material Review, ACO-ADM-102
  7. Establishing and Maintaining Policies and Procedures, ACO-ADM-103
  8. Public Reporting Requirements, ACO-ADM-104
  9. Beneficiary Engagement and Patient Centeredness, ACO-ADM-105
  10. Care Coordination, ACO-ADM-106
  11. Evidence Based Medicine, ACO-ADM-107
  12. Internal Reporting on Cost and Quality, ACO-ADM-108
  13. Participant and Provider/Supplier List Updates, ACO-ADM-109
  14. Repayment Mechanism, ACO-ADM-110
  15. Initial Beneficiary Notifications, ACO-ADM-111
  16. Code of Ethical Business Conduct, ACO-CMP-100
  17. ACO Compliance Plan, ACO-CMP-101
  18. Integrity Line, ACO-CMP-102
  19. Compliance Log, ACO-CMP-103
  20. ACO Board of Directors Conflict of Interest, ACO-CMP-104
  21. Non-Discrimination, ACO-CMP-105
  22. Compliance Program, ACO-CMP-106
  23. Compliance with Laws; Conflict of Authorities, ACO-CMP-107
  24. Compliance Officer Qualifications and Responsibilities, ACO-CMP-108
  25. Mandatory Education and Training, ACO-CMP-109
  26. Screening Prospective and Current IH ACO Caregivers and ACO Personnel, ACO-CMP-111
  27. Pending Charges Against IH ACO Caregivers and ACO Personnel, ACO-CMP-112
  28. Compliance Communications, ACO-CMP-113
  29. Non-Retaliation, ACO-CMP-114
  30. Duty to Report Compliance Concerns, ACO-CMP-115
  31. Responding to Compliance Concerns, ACO-CMP-116
  32. ACO Board of Directors and Shared Governance, ACO-CMP-117
  33. Corrective and/or Disciplinary Action and Programmatic Corrections, ACO-CMP-118
  34. Access to CMS Systems, ACO-CMP-119
  35. Beneficiary Discharge, Avoidance, and Referrals, ACO-CMP-120
  36. Yearly Risk Assessment and Monitoring and Auditing, ACO-CMP-121
  37. Beneficiary Incentives, ACO-CMP-122
  38. Beneficiary Enhancements, ACO-CMP-123
  39. Fraud, Waste, and Abuse Laws and Utilization of Waivers, ACO-CMP-124
  40. Compliance with HIPAA and Data Use Agreement (DUA) Requirements, ACO-CMP-125