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FDR OVERSIGHT SUPPORTTOOLS YOU CAN USE!TABLE OF CONTENTSOverview InformationFDR Oversight – High Level OverviewAppendix – Overview of FDR Compliance Requirements1.2.3.4.5.6.7.General Compliance InformationStandards of Conduct ChecklistOIG/GSA Exclusion ScreeningRecord RetentionMonitoring of Downstream EntitiesOffshore/LocationsAnthem’s Methods of Reporting Complianceand Fraud, Waste and Abuse2- 2411-23121314 – 1819202122-23Policy & Procedure TemplatesOIG/GSA Exclusion List Policy and ProcedureRecord Retention Policy and Procedure25-2627Forms2019 Offshore Subcontract Attestation TemplateFDR Disciplinary Actions Information Form28-3031-32General FDR Information2019 Anthem Contract ListingFDR Audit Readiness3435-36Medicare Regulatory Exhibit and Attachment One (1)(i.e. FDR Monitoring Survey)37-44Anthem’s FDR Annual Monitoring Survey45-49Ariba System New User Access Guide50-55Anthem Medicare FDR Program (Rev 12182018)1

First Tier, Downstream and Related Entity(FDR) Oversight - High Level OverviewThe FDR Oversight Program maintains high-leveloversight of Anthem’s contracted First Tier, Downstreamand Related Entities (FDRs) to ensure each FDR meetsapplicable CMS requirements.Meeting CMS RequirementsBusiness areas contracting FDRs maintain day to dayoversight.FDR Oversight Program aims to provide high leveloversight of FDR with assistance of businessowners/business unit via: Annual monitoring, auditing, andcommunication/education/ training efforts.The Appendix of this document contains a high leveloverview of Centers for Medicare and MedicaidServices (CMS) requirements.Requirements are also covered in the MedicareRegulatory Exhibit (MRE) of the FDR’s contract withAnthem.Anthem Medicare FDR Program (Rev 12182018)2

Medicare FDR Oversight - MonitoringFDR Monitoring ScheduleAll FDRs are assigned a monitoring month via theFDR Monitoring Schedule.Monitoring reviews begin the first (1st) day of assignedmonth and have a 30-day due date.Monitoring Survey FeaturesThe Monitoring Survey is issued electronically viaAriba a web-based tool.The Monitoring Survey is a compliancequestionnaire with support documentation requests.A signed FDR Attestation upon submission of theMonitoring is required from FDR Representatives.Business Owner Section- Contract Information- Corrective Action Plans(CAPs)/ComplianceCommunication Center(CCC)- Performance Metrics &Reporting Requirements- Readiness ActivitiesAnthem Medicare FDR Program (Rev 12182018)FDR Section- FDR Locations- FDR Offshore Locations- Code of Conduct/Compliance Policies- Reporting Compliance orFWA Concerns- OIG/GSA Federal Exclusions- Monitoring of DownstreamEntities- Record Retention- FDR Attestation3

Medicare FDR Oversight - MonitoringFDR Monitoring Form FeaturesAnthem Medicare FDR Program (Rev 12182018)4

Medicare FDR Oversight - MonitoringCompliance CategorizationCorrective Action Process FDR Oversight Team reviews the submittedMonitoring Survey. Feedback is issued via a web-basedRemediation Survey. All follow-up items and/or compliance gaps must beremediated before the FDRs monitoring cycle isclosed.Anthem Medicare FDR Program (Rev 12182018)5

Medicare FDR Oversight - MonitoringFDR Oversight WorkflowAnthem Medicare FDR Program (Rev 12182018)6

Medicare FDR Oversight – AuditAudit ProcessFocused FDR Audits are conducted to validate FDRsfulfilling CMS compliance program requirements, CMSrequirements specific to services provided and AnthemFDR expectations. The annual Medicare FDR Oversight AuditSchedule is approved by the FDR ComplianceCommittee and announced at the beginning ofeach year. The Audit Survey and requests are issued viaAriba a web-based system.Corrective Action Process FDR Oversight Team tracks and documents auditprogress. All information and documentation is reviewed bythe FDR Oversight Team. Initial feedback and additional requests are issuedvia a web-based Remediation Survey. Final audit report is issued to the Anthem BusinessOwner and FDR. All audit findings and/or additionalsupporting documentation requests must beaddressed by the Anthem Business Owner and FDR.Anthem Medicare FDR Program (Rev 12182018)7

Medicare FDR Oversight - Communication Kick-OffPacketPacket of documentation and tools to aidFDRs in compliance and understandoversight requirements Includes Anthem’s Standards of EthicalBusiness Conduct, Anthem’s MedicareCompliance Plan and FDR Oversight ToolKit. FDRNewsletterQuarterly electronic distribution to allAnthem Business Owners and FDRs. Content includes compliance information,updates to requirements, helpful tips andexamples.Business Owner Meeting/FDR TrainingPeriodic meeting with open invitation toAnthem Business Owners and FDRs. Used to provide education, training andaddress oversight questions. Monthly meeting with open invitationto Anthem Business Owners andFDRs.Used to provide education, training,and answer oversight questions.Monthly FDROversightClinic Anthem Medicare FDR Program (Rev 12182018)8

Medicare FDR Oversight – CommunicationKick-Off PacketDistribution Schedule To all FDRs at the start of anew year. During the FDR onboarding process. The document includes acopy of the FDR AnnualMonitoring Survey. Distributed whenever newdocumentation is issued byAnthem (i.e. CompliancePlan, etc.)Packet Also Includes Anthem’s Standards ofEthical Business Conduct(SOEBC) Anthem’s MedicareCompliance Plan FDR Oversight Support“Tools you Can Use” Kit.Anthem Medicare FDR Program (Rev 12182018)9

Medicare FDR Oversight – CommunicationQuarterly FDR NewsletterNewsletter Quarterly Distribution FDRs and internal business owners receive electronicallyon a quarterly basis. Educates stakeholders on key compliance updates torequirements and processes Features multiple articles, external links, and includesmethods of reporting compliance issues.Articles in Action Reporting for Duty: TheRequirement to Report NonCompliance and FWA. Keep Your Policies Healthy:A Check-Up for your P&Ps Checking in on OIG & GSAFederal Exclusion Checks Set your Standards High:Comply with Standards ofConduct, Policies &Procedures Requirements Read All About It! HighlightsHPMS memos released byCMS pertaining to FDRs.Anthem Medicare FDR Program (Rev 12182018)10

Appendix – Overview of FDRCompliance Requirements11

General Compliance InformationCMSRequirementFDRExpectation Compliance Policies and Standards of Conductmust be distributed to employees who supportMedicare Business. Distribution must occur: Within 90 days of hire When policy updates occur, and Annually thereafter Sponsors should ensure that standards ofConduct and policies are distributed to FDR’semployees. Sponsors may make their Standards of Conductand policies available to their FDRs. Alternatively, the Sponsor may ensure that theFDR has comparable policies and Standards ofConduct of their own. Anthem distributes our Standards of EthicalBusiness Conduct (SOEBC) and MedicareCompliance Plan to all FDRs. Distribution occursthrough Kick-Off Packet and FDR MonitoringSurvey. FDRs must make Anthem’s SOEBC andCompliance Plan available to all associatessupporting Medicare, or alternatively, make theirown comparable documents available. Distributionmethods can include: An email blast, Placement on an associate portal, Training content, etc. FDRs must be able to demonstrate distribution tostaff. In example: Email with visible distribution listing staff, or Communication sent to staff with Web location,etc.Anthem Medicare FDR Program (Rev 12182018)12

Standards of ConductAnthem Medicare FDR Program (Rev 12182018)13

OIG/GSA Federal Exclusion ScreeningCMSREQUIREMENTANTHEMEXPECTATIONS Sponsors must review theOIG list of ExcludedIndividuals and Entities(LEIE) and the GSAExcluded Parties ListsSystem (EPLS prior to thehiring or contracting of anynew employee, volunteer,consultant, governing bodymember, or FDR, andmonthly thereafter, toensure that none of thesepersons or entities areexcluded or becomeexcluded from participatingin federal programs. FDRs must screen allemployees supportingMedicare business prior tohire and monthlythereafter against both theOIG and GSA exclusionlists. FDR must maintaindocumentation to evidenceall pre-hire and monthlyemployee screenings. Sponsors shall not usefederal funds to pay forservices, equipment ordrugs prescribed orprovided by a provider,supplier, employee orFDR excluded by theDHHS OIG or GSA.MMCM Ch. 21 &PDBM Ch. 9 Sect. 50.6.8Anthem Medicare FDR Program (Rev 12182018) Proof of Screenings willbe required during AnnualMonitoring and mayinclude exclusionscreening screenshots,system generated reports,etc. At a minimum, evidenceshould show associatename (or identifier), dateof screening, and results. FDRs must have policies inplace for immediateremoval of staff verified asexcluded.14

OIG/GSA Federal Exclusion ScreeningAnthem Medicare FDR Program (Rev 12182018)15

OIG/GSA Federal Exclusion ScreeningOIG/GSA Exclusion Verifications – Sample of SupportDocumentationAnthem Medicare FDR Program (Rev 12182018)16

OIG/GSA Federal Exclusion ScreeningOIG/GSA Exclusion Verifications – Sample of SupportDocumentationAnthem Medicare FDR Program (Rev 12182018)17

OIG/GSA Federal Exclusion ScreeningAnthem Medicare FDR Program (Rev 12182018)18

Record Retention MedicareRegulatoryExhibit (MRE) Section“Inspection of Books andRecords” requires allrecords related to Medicareactivity must be maintainedfor a period of 10 years. 42 C.F.R. 422.504(i) and/or42 C.F.R. 423.505(i)) Sponsors are accountablefor maintaining records fora period of 10 years of thetime, attendance, topic,certificates of completion (ifapplicable), and test scoresof any tests administered totheir employees, and mustrequire FDRs to maintainrecords of the training ofthe FDR’s employeesAnthem Medicare FDR Program (Rev 12182018) FDRs should have policiesin place requiring at least10 years retention of allrecords,compliancerecords, records specific tofunction provided). Policy should includethe method of retention(i.e. electronic, offsitestorage, etc.)19

Monitoring Downstream Entities The sponsor must If the FDR subcontractsdevelop a strategy toservices to a delegatedmonitor and audit its firstvendor (in support oftier entities to ensure theyAnthem’s Medicareare in compliance with allbusiness), the FDR mustapplicable laws andbe monitoring allregulations, and to ensuresubcontractors to ensurethat the first tier entitiesthey are in complianceare monitoring thewith CMS requirements.compliance of the entities FDRs will be required towith which they contract.provide a listing of allsubcontractors Monitoring of first tiersupporting Anthem’sentities for complianceMedicare business duringprogram requirementsannual monitoring.must include an- FDRs should ensureevaluation to confirmthey can demonstratethat the first tier entitiesmonitoring ofare applyingsubcontractors and beappropriate complianceable to provide supportingprogram requirementsdocumentation as part ofto downstream entitiesthe FDR Monitoringwith which the first tierCycle.contracts.Anthem Medicare FDR Program (Rev 12182018)20