Code of Conduct and Compliance Policies

Don't have your own Code?

Feel free to distribute Moda Health Code of Conduct to your employees.

Medicare compliance department policies

Our Code of Conduct explains our compliance program.

Training

Don't have training in place?

No need to develop your own! CMS has made General Compliance and FWA training available for download.

Already have your own training in place?

Use this tool to evaluate if your training is equivalent to CMS'.

Proof of Training Completion

This sample log provides a way to document your employee's completion of CMS's General Compliance and Fraud Waste and Abuse Training OR modify it to record completion of your own training. You may also provide this log to your downstream entities (contractors) to use in monitoring their training completion.

Reporting Mechanisms

How do I report non-compliance or potential fraud, waste, and abuse (FWA) to Moda Health?

You must report, to Moda Health, non-compliance or potential fraud, waste and abuse concerns which impact Moda Health. This poster provides mechanisms for reporting such issues which impact Moda Health, directly to Moda Health. Feel free to publicize this throughout your organization so that your employees know how to report concerns which impact Moda Health.

Monitoring and Oversight

Downstream Oversight

You must conduct oversight of your downstream entities. Downstream entities are persons or entities (contractors/vendors) that you contract with to assist you in providing health care or administrative services for our Medicare members. Part of your downstream oversight activities may include requesting attestations from your downstream entities to monitor their compliance. Use this attestation to ensure those you contract with (and touch Moda Health's Medicare business) are compliant with the Medicare Compliance Program Requirements.

Exclusion Screenings

Where is the OIG LEIE?

Complete prior to hire/contracting and monthly screens of employees and downstream entities here.

Where is the GSA EPLS/SAM?

Complete prior to hire/contracting and monthly screens of employees and downstream entities here.

Offshore

How do I receive prior approval for offshore operations that include Moda Health Medicare member PHI?

You must receive prior approval from Moda Health before utilizing offshore operations that include the use of Moda Health Medicare member protected health Information (PHI). This includes offshore operations conducted by you, your organization or any of your subcontractors (downstream entities). Please notify your Moda Health Medicare Delegated Entity Coordinator or Medicare Compliance Officer to initiate the approval process at .