Community Care is committed to conducting its activities in a manner that complies with all applicable laws and regulations of Medicare Parts C & D. As part of an effective compliance program, the Centers for Medicare and Medicaid Services (CMS) requires Community Care to ensure FDRs performing administrative or health care services for Community Care also comply with all applicable laws and regulations. Therefore, Community Care has developed an attestation to validate that each contracted FDR has met CMS requirements.

My organization is contracted with Community Care to provide an administrative or health care function that relates to Community Care’s Medicare Parts C or D contract (s) as established in 42 C.F.R. § 422.504 (i) and the Medicare Managed Care Manual Chapters 9 and 21. 
 
Please complete this form by responding yes or no to each statement. If your organization responds no to any question, provide an explanation in the comments box.
 
I have the authority to attest for my organization, and I attest as follows: 
 

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* Code of Conduct: My organization has received, understands and will comply with Community Care's Code of Conduct or your own comparable Code of Conduct. Further, the Code of Conduct is made available to employees, subcontractors, board members, and volunteers within 90 days of hire/contracting, and at least annually thereafter.

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* Fraud, Waste, and Abuse (FWA) and General Compliance Training: My organization will fulfill its obligation to provide FWA and General Compliance Training. In addition, my organization will maintain training records for 10 years and will provide such records to Community Care upon request.

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* Reporting Mechanism for FWA and Compliance Issues: My organization will comply with the requirement to maintain a confidential FWA and Compliance reporting mechanism. This mechanism will be distributed and publicized for all employees and contractors to encourage reporting potential FWA and compliance concerns without fear of retaliation.

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* OIG and GSA Exclusion Screening: My organization will comply with the requirement to screen owners, officers, employees and subcontractors against the Office of Inspector General (OIG) List of Excluded Individuals and Entities (LEIE); and the General Services Administration (GSA) System for Award Management (SAM) at the time of hiring or contracting, and monthly thereafter.

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* Conflicts of Interest: My organization will comply with the requirement to identify, mitigate, or eliminate any conflict of interest.

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* Downstream Entities: If my organization subcontracts any services contractually delegated by Community Care that relate to its Medicare Parts C or D programs; my organization will ensure these contractors also comply with all applicable laws and regulations.

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* Record Retention and Availability: My organization understands and agrees to maintain supporting documentation for 10 years and will provide evidence to Community Care or the Secretary of the federal Department of Health and Human Services upon request.

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