Compliance Program

 

Banner Medicare Advantage is committed to ethical and legal conduct. This includes meeting the obligations of programs involving the delivery of health care services. Banner Medicare Advantage is a Medicare participant.

A key component of our commitment to meeting our obligations under governmental programs and contractual relationships includes adopting standards that uphold these principles, which is the basis for this Compliance Program. The Compliance Program is described in several documents including the Code of Conduct, policies and procedures, as well as the Fraud, Waste, and Abuse Plan.

All employees and the Governing Bodies as well as first tier, downstream and related entities, subcontractors, Providers and agents (Business Partners) must make a personal commitment to adhere to the Code of Conduct. Please review our Compliance Program and Fraud, Waste and Abuse Plan (January 1st through December 31st), which includes the Banner Medicare Advantage code of conduct.

Banner Medicare Advantage is committed to compliance and meeting requirements of all applicable laws and regulations of CMS. As part of our compliance program, please review the FDR Guide to help ensure your compliance with CMS, and Banner Medicare Advantage requirements.

Related Documents

2021 Compliance Program and Fraud, Waste and Abuse Plan

2021 FDR Guide

Compliance Handout

Banner Medicare Advantage General Compliance and FWA training is now available on our website. FDRs can take our training or a comparable training. FDRs are required to complete an attestation and submit it to BMA  indicating that the employees involved in the administration of Medicare Part C and D benefits have satisfied the training requirement.  In addition, the following are required training elements:

  • Detailed information about the Federal False Claims Act,
  • The administrative remedies for false claims and statements,
  • Any State laws relating to civil or criminal liability or penalties for false claims and statements, and
  • The whistleblower protections under such laws.

Documentation of internal training can be through an individual certificate or a list showing the information for all of those who completed it through the internal web-based training.

The Compliance Departments or Vendor Oversight Staff track completion of training by FDRs through the completion and collection of annual attestations from all FDRs.

Related Documents

2021 General Compliance Training for FDRs

 

The Code of Conduct states Banner Medicare Advantage's over-arching principles and standards by which Banner Medicare Advantage operates and defines the underlying framework for the compliance policies and procedures. Staff, Providers, and Business Partners, from the top to the bottom of our organization, have the responsibility to perform their duties in an ethical manner in compliance with laws, regulations and Banner Medicare Advantage policies.

Banner Medicare Advantage requires that all FDRs supporting the Medicare Advantage and Part D Prescription Drug Program adopt and abide by the Banner Medicare Advantage Code of Conduct or implement a Code of Conduct that incorporates standards of conduct and requirements consistent with Banner Medicare Advantage's Code of Conduct.

All Banner Medicare Advantage Staff and Business Partners must read the Code of Conduct annually and sign an acknowledgement that they agree to abide by the Code of Conduct.

Related Documents

2021 Code of Conduct

Contact our Compliance Department with any questions and/or to report potential compliance issues and fraud, waste, and abuse.

ComplyLine (Confidential and Anonymous): (888) 747-7989; 24 hours a day/7 days a week

Email: BHPCompliance@bannerhealth.com

Mail:
Banner Medicare Advantage
Compliance Department
2701 E. Elvira Road
Tucson, AZ 85756

Fax: (520) 874-7072

Compliance Officer:
Linda Steward, CHC
Director Corporate Compliance
Medicare Compliance Officer
(520) 874-2553

Related Documents

Compliance Issues or Fraud Waste or Abuse Report Form

Contracted providers and Subcontractors, with  Banner Medicare Advantage are required to complete the Annual Attestation and Disclosure Statement. 

Instructions:

1. Review each section

  • Section 1: Medicare and Medicaid Participation Compliance Program Requirements
  • Section 2: Attestations
  • Section 3: Organization Information and Signature

2. Complete the 2021 Annual Attestation online here: https://eservices.uph.org  

*If you are unable to complete the online form above, below is the PDF version.

2021 Annual Attestation Form

3. Complete the Offshore Subcontracting Attestation if contracting with offshore entity.

2021 Offshore Subcontracting Attestation

Banner Medicare Advantage is committed to preventing Fraud, Waste, and Abuse (FWA).

If you suspect a provider or member of fraud and abuse, please contact us at any of the following methods:

Phone
Customer Care Center: (844) 549-1859; TTY users call 711.
ComplyLine (Confidential and Anonymous): (888) 747-7989; 24 hours a day/7 days a week.

Mail
Banner Medicare Advantage
Compliance Department
2701 E. Elvira Road
Tucson, AZ 85756

Fax
(520) 874-7072

Email
BHPCompliance@bannerhealth.com

Examples of Fraud, Waste, and Abuse

Member Fraud, Waste, and Abuse include, but are not limited to:

  • Lending or selling your Health Plan Identification Card to anyone.
  • Using someone else's Health Plan card to obtain services.
  • Changing prescriptions written by any Banner Medicare Advantage provider.
  • Not stating true income or living arrangements.
  • Providing false materials or documents.
  • Leaving out important information.
  • Failing to report another insurance that you have.
  • Continuing to use CMS for services when you move out of the state or out of the country.

Provider Fraud, Waste, and Abuse include, but are not limited to:

  • Ordering tests, lab work, or x-rays that aren't needed.
  • Charging for medical services not provided.
  • Billing multiple payers and receiving double payments.
  • Using billing codes that pay higher rates to get more money even though those services weren't provided.
  • Billing for services under a member who is not their member.
  • Providing unnecessary medical services leading to unnecessary costs to the program.
  • Use of the Medicare system by someone who is unqualified, unlicensed, or has lost their license.

BMA has written policies in place to:

  • Articulate our commitment to comply with all applicable Federal and State standards;
  • Describe compliance expectations as embodied in the Standards of Conduct;
  • Implement the operations of the Compliance Program;
  • Provide guidance to Staff and Business Partners on dealing with suspected, detected or reported compliance issues;
  • Identify how to communicate compliance issues to appropriate compliance personnel;
  • Describe how suspected, detected or reported compliance issues are investigated and resolved by our company; and
  • Include a policy of non-intimidation and non-retaliation for good faith participating in the Compliance Program, including, but not limited to reporting potential issues, investigating issues, conducting self-evaluations, audits and remedial actions, and reporting to appropriate officials

Related Documents

CP 5001 Compliance Program

CP 5004 Reporting Compliance Issues

CP 5007 Protected Health Information

CP 5014 FDR Oversight

CP 5018 Fraud, Waste and Abuse

CP 5019 Fraud, Waste and Abuse Awareness for FDRs

CP 5023 Code of Conduct

CP 5024 Conflict of Interest 

CP 5032 Offshore Outsourcing

CP 5033 Sanction Screening

CP 5108 Compliance Actions

CP 5221 Compliance Officer Responsibilities

CP 5227 Monitoring and Auditing