COMPLIANCE

American Specialty Health (ASH) contracts with Medicare Advantage and Medicaid Managed Care plans to provide benefits to their members. Because these programs are paid for with federal and/or state tax dollars there are specific compliance requirements that the Medicare Advantage and/or Medicaid Managed Care plans require ASH and its contracted practitioners meet.

COMPLIANCE REQUIREMENT TIMELINE

 

1. GENERAL COMPLIANCE AND FRAUD, WASTE, AND ABUSE TRAINING

Required annually and within 30 days of hire for owners, managers, and key employees

You may provide the training in your office by using the below ASH materials, or a substantially similar training, and complete the Employee Roster.

Review General Compliance And Fraud, Waste, and Abuse Training Every year, billions of dollars are improperly spent because of non-compliance and Fraud, Waste and Abuse. It affects everyone-including you. This training will help you detect, correct, and prevent non-compliance and Fraud, Waste and Abuse.  
Print & Complete Employee Roster for General Compliance and Fraud, Waste & Abuse Training

2. EXCLUSION FROM MEDICARE AND MEDICAID CHECKS

Required for owners and managers monthly and prior to hire of new key employees

Exclusion Checks You, as a contracted practitioner, must run all employees that provide health or administrative services to Medicare and/or Medicaid beneficiaries through the List of Excluded Individuals/Entities (“LEIE”) maintained by the Office of the Inspector General (OIG), the System for Award Management (“SAM”) maintained by the General Services Administration (GSA) and any state published Medicaid exclusion lists (collectively “Exclusions Lists”) prior to hire or contracting and monthly thereafter. For more information on how to access the Exclusion Lists mentioned above, please refer to the Exclusion Checks Guide. If you hire an individual or entity on any of the Exclusion Lists, you may be subjecting ASH and its contracted Medicare Advantage or Medicaid Plan clients to civil monetary penalties (CMP). As such, it is important to run these checks prior to hiring or contracting with a new individual. It is also important to run the subsequent monthly checks in a timely manner. If you find an employee on any of the Exclusion Lists while running a check, please notify ASH immediately via ASH’s Anti-Fraud Hotline at 1.877.427.4722.  
Review Exclusion Checks Guide
Complete Exclusion from Government Program Checks

3. ASH POLICIES

Required annually and within 30 days of hire for owners, managers, and key employees

Code of Conduct & Ethics
Review Code of Conduct & Ethics Program ASH’s Code of Conduct and Ethics Program outlines standards and guidelines for behavior in specific situations. As a symbol to ASH’s commitment to ethical practices, the program was designed to build a foundation of trust with clients, practitioners and the tens of millions of members we serve. The materials for ASH’s Code of Conduct and Ethics Program are materials all ASH employees receive when they are hired and annually thereafter. These are being provided as educational, no training or follow-up is needed on your part. Practitioner needs to sign receipt under step 4: Consolidated Attestation.  

Reporting Issues of Noncompliance
Compliance Issue Reporting Form To report suspected issues of noncompliance, please call the Ethics and Integrity Hotline at 866-998-2746. In addition to the Hotline and to assist you with reporting your concerns you may also complete the Compliance Issue Reporting Form available below and submit it electronically to the Ethics and Integrity Hotline email at ethicsandintegrity@ashn.com  

4. CONSOLIDATED ATTESTATION

Required annually for owners and managers

Consolidated Attestation Annually, all contracted practitioners are required to complete attestations regarding the following compliance areas: General Compliance and Fraud, Waste and Abuse Training, Exclusion from Medicare and Medicaid Checks, Code of Conduct and Ethics Program (inclusive of conflict of interest issues) and Record Retention requirements. ASH has provided a consolidated attestation for all areas of compliance. Please complete this attestation and save it in your records as ASH may request a copy of the attestation at any time.  
Print & Sign Consolidated Attestation

5. RETAIN RECORDS

You are required to maintain a copy of the Employee Roster for General Compliance and Fraud, Waste & Abuse Training, Exclusion from Medicare & Medicaid Checks Monthly Log and Roster, and the signed Consolidated Attestation for a period of 10 years.