Important Contractor and Vendor Compliance Requirements

As a Tufts Health Plan vendor that provides services to assist us in the administration of Medicare Part C and Part D benefits, you are subject to compliance program requirements specified by the Centers for Medicare & Medicaid Services (CMS) under 42 CFR §422.503 and 42 CFR §423.504. CMS holds Tufts Health Plan responsible for ensuring that you meet these requirements, some of which include:

• Having "standards of conduct" that you distribute to your employees;*
• Providing general compliance training and fraud, waste & abuse (FWA) training to employees, upon hire and annually thereafter;*
• Providing a well-publicized system for employees to report non-compliance and FWA;*
• Having well-publicized disciplinary standards;*
• Documenting disciplinary and corrective actions;
• Not employing or subcontracting with anyone on federal exclusion lists and checking such lists upon hire and monthly; and
• Maintaining records related to all of the above for 10 years.

We realize that some vendors, depending on their size and other factors, may not routinely have processes and materials in place to meet each of these requirements. To assist you, Tufts Health Plan is providing you with materials to help meet some of these requirements, indicated by an asterisk [*] above. You may use or adapt these materials, or you may use your own materials.

If you have any questions about these requirements or materials, please contact your Tufts Health Plan business contact or Mike Gustin at 617-972-9400, x3113.

Thank you in advance for assisting Tufts Health Plan in meeting CMS compliance program requirements.