Government Programs compliance tips

This checklist will help ensure you are compliant with the Government Programs requirements for delegated and downstream entities (DDEs).

You are required to maintain documentation sufficient to demonstrate to us or the Centers for Medicare & Medicaid Services (CMS) that these elements are met.

Before hiring a new employee or governing body member

Check both the Office of Inspector General (OIG) and General Services Administration (GSA) federal exclusion lists to ensure that no employees are excluded from participation in federal programs. The term "employees" includes temporary employees, volunteers and consultants. If applicable, establish a process to identify and prevent payment for claims at point-of-sale for any drugs or services prescribed, dispensed or delivered by excluded providers.

Within 90 days of hire

  • Provide your organization's standards of conduct and policies and procedures to all employees who provide administrative services or health care services for BridgeSpan members. If your organization does not have its own code of conduct, please use Cambia's.
  • Require governing body, officers and senior leadership (as applicable) to sign a conflict of interest disclosure.
  • Provide fraud, waste and abuse (FWA) training to all employees who provide administrative services or health care services for BridgeSpan members.
  • Provide general compliance training to all employees who provide administrative services or health care services for BridgeSpan members.

Monthly for all employees and governing body members

  • Check both the OIG and GSA federal exclusion lists to ensure that no employees have become excluded from participation in federal programs.

Annually for all employees and governing body members

  • Provide standards of conduct and policies and procedures to all employees who provide administrative services or health care services for BridgeSpan.
  • Require governing body, officers and senior leadership (as applicable) to sign a conflict of interest disclosure.
  • Provide fraud, waste and abuse training and general compliance to all employees who provide administrative services or health care services for BridgeSpan.

Report all compliance concerns

For concerns regarding ethics, compliance or fraud, contact us through one of these confidential options:

  • Fraud, waste and abuse: 1 (800) 323-1693
  • Anonymous reporting line: 1 (888) 384-3577
  • For questions or concerns related to compliance, privacy, HIPAA compliance or ethics: 1 (877) 878-2273