The Medicare Compliance Program requirements described herein apply to all participating Providers contracted with NationsHearing to provide services to Medicare participants. This includes audiologist, hearing aid specialist, hearing aid dispensers, hearing instrument specialist, and other provider types.
NationsHearing is considered a First-Tier entity as we provide administrative and health care services for Medicare plans. As a First-Tier entity, we are responsible for complying with relevant Medicare program requirements. We must also ensure that our Downstream Entities, comply with applicable laws and regulations, including the requirements outlined below. If you or your organization is contracted or intends to contract with NationsHearing for participation in our Provider network, you are considered an FDR (specifically, Downstream Entity of NationsHearing) under CMS guidelines.
Your organization must comply with NationsHearing compliance program requirements. This summarizes the compliance program requirements. NationsHearing obtains an annual attestation from our Providers to ensure compliance with applicable program requirements. An authorized individual must attest that its organization is in compliance with requirements relating to the following:
You may be asked to provide evidence of compliance. In addition to completing an attestation, NationsHearing may request that you provide evidence of your compliance. This is for monitoring/auditing purposes. We take these responsibilities seriously. If you have questions or concerns about these compliance program requirements, just contact NationsHearing.
The “Toolbox of Resources” may help you meet these requirements.
You can find the CMS general compliance training module on the CMS Medicare Learning Network (MLN). It can be completed on the MLN, after registration. It is titled Medicare Parts C and D General Compliance Training. You can also download it and incorporate the module, unmodified, into your existing training materials/systems.
CMS requires FDRs to maintain evidence of training completion. FDRs must retain this evidence for 10 years. The CMS training completion certification is evidence of completion. This sample log also provides a way to document your employees’ completion of training.
Not every employee always needs to complete training. This grid has examples of FDR employees that do and don’t need to complete it.
Feel free to distribute NationsHearing’s code of conduct to your employees.
NationsHearing’s code of conduct explains our compliance program, but contact email@example.com for policies that provide more detail about our Medicare compliance program.
Complete OIG exclusion list screenings before hiring/contracting and monthly after that for your employees and Downstream Entities.
Complete the GSA’s SAM exclusion list screenings before hiring/contracting and monthly after that for your employees and Downstream Entities.
This poster provides ways for reporting issues directly to NationsHearing. Feel free to share this throughout your organization so that your employees know how to report concerns. Remember, you must report suspected or detected noncompliance or potential FWA that impact Medicare Health Plans.
You must conduct oversight of your Downstream Entities. This may not be applicable to all Providers / FDRs.
Submit the Medicare Compliance Program Guidelines Attestation for Downstream Entities (Providers) to firstname.lastname@example.org or through our Portal, upon NationsHearing’s request. This attestation must be completed by an individual in your organization who has signatory authority to make the representations in the attestation.
If you have ideas for tools that would help you in meeting the Medicare compliance program requirements, send an email to email@example.com
If you have a question that we didn’t answer in this guide, please contact firstname.lastname@example.org
CMS provides a variety of Medicare and Medicaid related educational tools and other resources at www.cms.gov. Below are some links to the tools/resources applicable to FDR requirements:
NationsHearing has safeguards in place that protect any individual who reports a concern in good faith from retaliation. To the extent possible, reports are kept confidential and anonymous reporting is available through the NationsHearing Compliance hotline.
Call the NationsHearing Compliance Hotline Toll-free (877) 391-1553
Email at email@example.com
Write to NationsHearing’s Compliance Department at:
Attn: Compliance Department
1700 North University Drive
Plantation, FL 33322