Introduction

Centers for Medicare & Medicaid Services (CMS) requires health plans and its First-Tier Downstream Related entities (FDRs) to comply with specific annual compliance program. My organization is a FDR of Optum and am therefore required to train and attest annually. 
 
The provided links to 2022 courses enable us to meet the requirements in the event my organization does not already have one in place. 

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* 1. COMPLIANCE PROGRAM:
My organization requires all employees to complete the following items or an equivalent within 90 days of hire and annually thereafter.

A. OIG-GSA Exclusions:
My organization ensures that none of our employees, contractors or downstream entities that service Optum/UHG business are on the HHS Office of Inspector General (OIG), the General Services Administration (GSA), System for Award Management (SAM) exclusion lists, or any applicable state exclusions lists prior to hire, or contracting, and monthly thereafter. Documentation of pre-hire/contract and monthly screenings are maintained for at least 10 years.

B. Offshoring:
My organization does not engage in offshore operations for Optum related Medicare business without the express consent of an authorized Optum representative since these activities, if involving the receipt, viewing, processing, transferring, handling, storing or accessing of PHI, must be reported to CMS. Optum either has already been notified of any such offshore arrangements, or we will notify as necessary by completing the FDR Offshore Sub-Contractor Attestation form and submitting to FDROversightCA@optum.com.

C. Compliance Officer/Representative:
My organization maintains a designated compliance officer or representative.

D. Indicate Start of Training Date and Time below before moving on to Step 2:

Date
Time

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* 2. HEALTH PLAN TRAINING: 
A. Contractual Requirements with Optum's health plans require that we, as contracted IPA Providers, have completed training topics provided.

B. Minimum Requirement for Training Timeframe is: *1 hour between:
   Step 1D above, Start of Training Date and Time; and
   Step 2C below, Completion of Training Date and Time:
   *Unless my organization can evidence that all provided training or its equivalent were completed in 2022 upon request.
C. Indicate Completion of Training Date and Time Below:

Date
Time

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* 3. ATTESTATION:
A. I attest that my organization has provided this training, or an equivalent, and has met the requirements above for all our employees, contractors, and downstream entities in 2022 and maintain records of completed training for at least 10 years.

B. Check the box next to "I Agree" Statement.

Please contact FDROversightCA@Optum.com if you have any questions.

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* 4. Tax ID # in XX-XXXXXXX format

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* 5. Vendor / Practice Name

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* 6. Your Name

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* 7. Email Address

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* 8. Phone Number

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