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Overview

The Helper Bees contracts with vendors as a cost-effective and efficient way of providing administrative and health care services to our members. We are required to perform these services under our contract(s) with our plan sponsors and CMS guidelines.
All service providers, contractors, subcontractors, and vendors must undergo a pre-delegation assessment prior to performing delegated activities or providing services. This assessment includes evaluation against certain specific criteria, carefully considered by The Helper Bees Management, Legal, and Compliance teams. A first tier, downstream, and related entities (FDR) can be identified as any entity meeting some or all of the following criteria:
  • The Helper Bees is required to provide this function under its plan sponsors contract(s), federal regulations, or CMS guidance
  • The function directly impacts members or prospective members
  • The entity interacts directly with members or prospective members either orally or in writing
  • The delegated entity has access to beneficiary information or personal health information (PHI or PII)
  • The delegated entity has decision-making authority (e.g., enrollment vendor deciding time frames) or whether the entity strictly takes direction from the sponsor
  • The delegated entity is in a position to potentially commit health care fraud, waste, or abuse (FWA)
  • There is risk that the entity could harm enrollees or otherwise violate CMS program requirements or commit FWA

Contract Requirements

The Helper Bees negotiates various types of agreements with vendors, depending on the delegated services and line(s) of business. These include, but are not limited to, agreements with contractors, providers, and facilities; general agencies; and include corporate master service agreements, administrative agreements, and statements of work. Should any new responsibilities be added or removed from an FDR agreement, our Plan Sponsor Account Managers are responsible for notifying and working with our Legal and Compliance Teams for facilitation of such changes.

Compliance Program Requirments

What are the elements of an effective compliance program?
FDRs are required to develop and implement a comprehensive and effective compliance program. There are seven “elements” to this program that must be implemented. During our pre-delegation assessment, we review each FDRs compliance program to ensure that these elements are in place.
An effective compliance program should include
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Exclusions Screening

Federal law prohibits Medicare, Medicaid, and other federal health care programs, from paying for items or services provided by a person or entity excluded from participation in these federal programs. Therefore, before hiring or contracting, and monthly thereafter, each FDR must check exclusion lists from the Office of Inspector General (OIG) List of Excluded Individuals and Entities (LEIE) and the U.S. General Services Administration (GSA). This is to confirm that employees, board members, and Downstream Entities performing administrative and/or health care services are not excluded from participating in federally funded health care programs.
FDRs can use the following websites to perform the required exclusion list screenings:

Oversight, Reporting, Monitoring and Auditing Requirements

General requirements related to fdrs performing delegated functions
General requirements related to fdrs performing delegated functions
Requirements related to provider invoicing of cnacelled, missed, or otherwise unfulfilled services
Requirements related to provider invoicing of cnacelled, missed, or otherwise unfulfilled services
Requirements related to unsuccessful audits of provider invoicing
Requirements related to unsuccessful audits of provider invoicing
corrective actions
corrective actions

Summary

Ami or is my company a first tier, downstream, or related entity (FDR) of the Helper Bees?
Ami or is my company a first tier, downstream, or related entity (FDR) of the Helper Bees?
What are my / my comany’s responsibilities as an fdr of the Helper Bees
What are my / my comany’s responsibilities as an fdr of the Helper Bees

For Questions & Contact

We hope that the information in this document has been helpful and has effectively communicated ongoing oversight, monitoring, reporting and other compliance expectations to all our CMS Compliance Partners.
For Questions or concerns regarding this guide, please contact:
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TO Report any suspected or actual compliance violations please contact
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For Fraud waste and abuse
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For Privacy
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References
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