NHC Advantage Compliance
We are committed to acting with integrity and making decisions based on the highest standards of ethical behavior, including complying with applicable laws and regulations.
To ensure the provision of quality health care services in compliance with these laws, NHC Advantage has developed a Compliance Program that provides guidelines and assigns responsibilities for controls and procedures that promote consistent and proper organizational behavior.
The Compliance Program has been developed to assist in establishing a culture within NHC Advantage that promotes the prevention, detection, and resolution of instances of conduct that do not conform to federal and state law and federal and state health care program requirements.
The Compliance Program describes our commitment to ethical business practices and behavior. Additionally, the Compliance Program provides the framework to assure that our employees, including officers, managers, volunteers, interns, Board of Directors, vendors (contractors, subcontractors), and first-tier, downstream, and related entities (FDRs) comply with the applicable legal and ethical standards of conduct, including our standards of conduct and requirements to prevent, detect, and mitigate fraud, waste, and abuse (FWA).
Standards of Conduct
NHC Advantage has implemented Standards of Conduct which state the overarching principles and values by which NHC Advantage operates and defines the underlying framework for the NHC Advantage Compliance Program. The Standards of Conduct communicate that compliance is everyone’s responsibility.
The NHC Advantage Standards of Conduct describes our expectations that:
- All employees and first tier, downstream, and related entities (FDRs) conduct themselves in an ethical manner.
- Issues of noncompliance and potential fraud, waste, and abuse (FWA) are reported through appropriate mechanisms.
- Reported issues will be addressed and corrected.
Medicare FWA & General Compliance for FDRs
NHC Advantage contracts with the Centers for Medicare and Medicaid Services (CMS) to provide health care and prescription drug benefits under Medicare Advantage and Medicare Part D programs to our Medicare beneficiaries. As a part of these contracts, CMS requires NHC Advantage to oversee FDRs who provide health care or administrative services.
FDRs are an important partner in the continued success of our Compliance program.
The Plan’s vendors and FDRs must comply with the NHC Advantage Compliance Program and the Fraud, Waste, and Abuse policy. All FDRs who provide administration or health care services under contract with the Plan are also responsible for following NHC Advantage’s compliance policies and procedures. FDRs may either adopt the Plan’s Standards of Conduct or implement their own policies, procedures, and standards of conduct that adhere to the Plan’s. NHC Advantage has the right to review and approve FDR policies, procedures, and Standards of Conduct.
NHC Advantage’s policies and procedures are provided to vendors and FDRs in the form of manuals, policies, and procedures documents and training materials. These documents may be distributed by, but not limited to, the following methods: e-mail, fax, website, portal, or by other means, as appropriate. Periodic monitoring of the FDRs, including review of their compliance policies and programs and Standards of Conduct, also occurs.
Medicare requires FDRs to participate in the NHC Advantage Compliance Program, and we are committed to providing FDRs with the tools needed to ensure FDRs meet the obligations of this program.
While Medicare FWA and General Compliance training for FDRs is not required by the Centers for Medicare and Medicaid Services (CMS), FDR agents (e.g., office staff and other personnel associated with or employed by an FDR) are expected to be in compliance with all applicable laws, rules, and regulations, and Medicare requirements.
Contact the NHC Advantage Compliance Officer at [email protected] with any questions about the NHC Advantage Compliance Program.
Compliance Hotline: 1-844-317-9059 (toll free)
NHC Advantage has implemented a Compliance Hotline for our Members; employees; first-tier, downstream, and related entities; and other contractors and agents.
The Compliance Hotline provides a mechanism for callers to report activity related to known or suspected non-compliance with NHC Advantage’s mission; policies and procedures; Compliance program; Standards of Conduct; or any Federal, State, or local laws and regulations.
All calls to the Compliance Hotline will be treated as confidential and private to the fullest extent possible.
Compliance Hotline: 1-844-317-9059 (toll free)
If you are not comfortable or able to make a report via the Compliance Hotline, you may send a written report by mail to:
PO Box 5849
Glen Allen, VA 23058-5849
Or Email: [email protected]
Or Fax: 1-833-610-2380
Whether reporting by telephone or in writing, please provide as much detail as possible, including, but not limited to, names, dates, times, locations, and the specific conduct you feel may violate the law or NHC Advantage Policy.
No individual making a good faith report of a suspected violation shall be retaliated against. However, any individual who knowingly makes a false allegation shall be subject to disciplinary action in accordance with NHC Advantage Policy.