The Helper Bees created this guide to communicate specific compliance expectations for our service providers, contractors, subcontractors, and vendors who provide, oversee, or support delegated services to our members. Providers are expected to complete this attestation every year.
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 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.
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.
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:
The Helper Bees Compliance Team will perform pre-delegation and routine audits of an FDR’s Compliance Program based on risk assessment criteria. Compliance program audits include initial vendor assessment and pre-delegation audits, contract review, and review of specific validation documentation provided to The Helper Bees Compliance Team by the FDR’s Compliance and Audit team(s).
In addition, The Helper Bees Compliance Team will request FDRs to complete a Statement of CMS Compliance Attestation, which is included along with this guide on an annual basis.
Yes, if you or your company has a written arrangement with The Helper Bees, or you have an arrangement with a company contracted with The Helper Bees to provide:
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.
