CTS Compliance Program 2019 - PowerPoint Presentation

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CTS Compliance Program

2019

New Hire and Annual Employee Compliance Training

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CTS Introduction

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Coordinated Transportation Solutions, Inc.

CTS is a 501(c)(3) not-for-profit entity founded in Connecticut in 1997. We manage non-emergency transportation programs for government agencies, managed care organizations, school districts and businesses throughout the northeast and mid-Atlantic region. We do not have drivers and vehicles of our own that perform trips. Rather, we coordinate transportation using a network of credentialed and contracted, local transportation companies.

NEMT – Non-Emergency Medical Transportation

NET – Non-Emergency Transportation

CTS serves state departments of Medicaid and Health Plans that manage care for individuals eligible for Medicaid and Medicare.

Our Health Plan Clients hold Medicaid/Medicare contracts with the state. Part of their responsibility is to provide access to healthcare, through transportation, to eligible members. As a part of our Client’s responsibilities, they delegate to CTS the transportation services CTS is tasked with establishing and monitoring a network of Transportation Providers, Taking Member Calls for Bookings, Securing Rides for Eligible Members for Covered Locations and Appointments, Submitting Claims and Payment, Reporting, and customizing each program to meet Client-specific rules for their Members.

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Who is CTS

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Medicare

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Medicare

Medicare

i

s a national health insurance program in the United States, begun in 1966 under the Social Security Administration and now administered by the Centers for Medicare and Medicaid Services. It provides health insurance for Americans aged 65 and older.

Original Medicare vs. Medicare Advantage

Medicare Advantage is Managed Care, administered by our Clients.

Medicare Advantage often times offers additional benefits that Original Medicare can’t, which makes this option more attractive for Members.

Medicare members that also qualify for Medicaid, are

‘dual eligible,’

meaning that those people have Medicaid Benefits and Payment Coverage after the Medicare Coverage has been used first.

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CENTERS FOR MEDICARE AND MEDICAID SERVICES

Original Medicare

Part A hospital coveragePart B outpatient, or regular Doctor office coverage Part C is Medicare Advantage – MA combines Part A & Part B, and often times Part D (MA-PD) into one program that Insurance Companies AdministerPart D Pharmacy coverage

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Medicaid

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Medicaid

Medicaid

– is a joint federal and state program that helps with medical costs for some people with limited income and resources. Medicaid also offers benefits not normally covered by Medicare, like nursing home care and personal care services.

Non-Emergency Medical Transportation to and from doctor appointments have been a long-standing Medicaid required benefit, instituted by federal regulation.

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Each State has their own Medicaid Program – In Connecticut, the Medicaid programs are called HUSKY A, HUSKY C, and HUSKY D.

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CENTERS FOR MEDICARE AND MEDICAID SERVICES

Transportation Services valued approx. USD 79.5 billion in 2017

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3.6 million Americans still miss or delay care each year due to transportation issues

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General Compliance

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Compliance

Compliance Programs are designed to ensure Companies remain within the bounds of the law, governmental regulations, and contractual requirements.

In 1991, The U.S. Sentencing Commission established the Seven Elements for an Effective Compliance Program. Many of those same strategies are utilized in healthcare compliance.

Compliance is staying within the rules of the company, preventing violations, promptly reporting violations when detected, and correcting violations as soon as possible.

 

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Regulations, Contracts, Ethics, and Reporting

Examples of Non-Compliance

Anything Outside What You Were Trained To Do

Fraud, Waste, and Abuse is spending outside proscribed guidelines

Unauthorized Disclosure of Personal Health Info (PHI)

Conflict of interest

Not Following Company Policies and Procedures

Violations of the Employee Handbook

Penalties of Non-Compliance Contract Termination – lost businessCriminal penaltiesCivil monetary penaltiesExclusion

Termination

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Seven Basic Elements of

Compliance

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Compliance

1. Written Policies, Procedures, and Standards of Conduct

2. Compliance Officer, Compliance Committee, and High-Level Oversight

3. Effective Training and Education 4. Effective Lines of Communication 5. Well-Publicized Disciplinary Standards

6. Effective System for Routine Monitoring, Auditing, and Identifying Compliance Risks

7. Procedures and System for Prompt Response to Compliance Issues

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SEVEN BASIC ELEMENTS

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Fraud, Waste, and Abuse

FWA

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Fraud, Waste, and Abuse

Fraud

:

•

Knowingly

billing for services not furnished or supplies not provided, including billing for appointments that the driver failed to make; • Forging Member Signatures implying Rides were made; and •

Knowingly altering claim forms, mileage records, or timestamps to get a higher payment.

Waste

:

• Member has a car for F|F Program, but continues to us Taxi/Livery;

• Scheduling multiple rides in anticipation of getting an appointment time; and

• Canceling rides without at least a hour notice.

Abuse: • Billing for unnecessary, scenic routes;

• Stopping at multiple locations before scheduled destination; • Charging excessively for a higher transportation mode than supplied; and

• Transportation Providers accepting as many rides as possible and rejecting less expensive rides at the end of the day prior to those trips. 12

WHAT’S THE DIFFERENCE

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Fraud, Waste, and Abuse

How Do You Prevent FWA?

• Look for suspicious activity

• Conduct yourself in an ethical manner

• Ensure accurate booking and Provider securement;

• Verify all information provided to you; and

• Remember your Training.

Report FWA

Everyone must report suspected instances of FWA. There is a policy of anti-retaliation for making a good faith effort in reporting.

Do not be concerned about whether it is fraud, waste, or abuse – Just report any concerns to your compliance department or anonymously through the Ethics Hotline.

Compliance will investigate and make the proper determination.

Correction

Once fraud, waste, or abuse has been detected, it must be promptly corrected. Correcting the problem saves the Government money and ensures you are in compliance.

Develop a plan to correct the issue. Compliance will complete the corrective action plan development.

•Design the CAP to correct the root cause of the program violations and to prevent future non- compliance; •Tailor the CAP to address the particular FWA, problem, or deficiency identified. Include timeframes for specifications; •Document non-compliance or FWA committed by an employee or Transportation Provider and include consequences for failure to complete the CAP; and

•Once started, continuously monitor CAPs to ensure they are effective.

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Prevent, Detect, Report, Correct

When in Doubt, report to the Compliance Department or Ethics Hotline.

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Examples

Owner of Rite Way Transport charged with laundering $19M in Medicaid Fraud

Before it closed in 2015, the company mainly drove MassHealth members to methadone clinics. The owner of Rite Way LLC, was initially charged in 2016 with fraudulently billing MassHealth $19 million for transportation that never occurred.

The company is accused of making fraudulent claims for non-emergency wheelchair van transportation and bribing MassHealth employees to recruit others to use Rite Way services, according to a press release from Attorney General Maura Healey’s office.

Albany transport company owner sentenced for Medicaid Fraud

The co-owner of an Albany transportation company,

Ammediate Transport fraudulently billed Medicaid for over $50,000 for rides that never happened. He was convicted of grand larceny and sentenced to two to four years in prison.

He admitted to setting up “ghost rides”, in which he would bill Medicaid for transporting fake patients to physical therapy appointments.

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FRAUD SCHEMES

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Health Information Portability and Accountability Act of 1996

HIPAA

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HIPAA

Health Insurance Portability and Accountability Act (HIPAA)

HIPAA created safeguards to prevent unauthorized access to protected health care information. As an individual with access to protected health care information, you must comply with HIPAA.

 

CTS does handle PHI in terms of the Member’s name, address, phone number, medical ID Number, doctor information, and location information.

It only takes a small amount of PHI to identify a Member; Once disclosed, the Member could have their health information exposed, claims submitted under their name/ID number, identity could be stolen, and/or more criminal acts.

It is

PARAMOUNT

as an employee of CTS, to protect all member information at all costs.

Verify who the Caller is

Never disclose another Member’s information to a Caller

Shred documents/paper with Member PHI on it

Secure/Lock Computer Screens and Desk Drawers with PHI

16PROTECTED HEALTH INFORMATION (PHI)

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HIPAA Safeguard Measures

Secure Computer

Always Lock your Computer when Leaving Your Workspace.

Use ‘

Ctrl+Alt+Del

’ or ‘ +L’ to Lock your Screen. Change and Save PasswordsKeep your Password Confidential and Change it often with a combination of letters, numbers, and alphanumeric symbols

Secure Email

CTS has the ability to send email secure and encrypted through the ZixMail

feature – Additionally emails are encrypted when ‘[Secure]’ is entered in the Subject Line.

Always Secure Email Containing PHI

Record Retention

For Audits and other Retrospective reviews, CTS must store Documentation Medicare – 10 years | Medicaid – 7 yearsShred Documents with PHI

PHI is not to leave the office – SHRED IT! Place it in the Shred bins located around the office

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ADOPT THESE BEHAVIORS

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Exclusions

OIG LEIE and SAM

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Government Participation

The

OIG

excludes individuals and entities from federally funded health care programs in the

LEIE

. No Federal health care program payment may be made for any service furnished by an individual or entity excluded by the OIG.

SAM is a Federal Government website that consolidates the exclusion databases, including EPLS.

Exclusion records identify those parties excluded from receiving federal contracts and from certain types of federal financial assistance and benefits.

Administrating Entities must check both the

LEIE

and the EPLS since the lists are not the same.

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EXCLUSION CHECKS AND DATABASES

OIG – Office of the Inspector General

LEIE – List of Excluded Individuals and Entities

SAM – System for Award Management

EPLS – Excluded Parties List System

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LAWS

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Notable Laws and Statutes

False Claims Act

Cannot Submit False or Fraudulent Claims for Goods or Services

Anti-Kickback Statute

Prohibits Soliciting and Receiving Remuneration for Referrals

Stark Law

Doctors Cannot Refer Members to Facilities They Have Ownership Interests In

Healthcare Criminal Fraud

Protects Against Fraud Schemes

Civil Monetary Penalty Law

Allows for Money Penalties as a Result of Committing the Offenses Above

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MAINTAIN PROGRAM INTEGRITY

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False Claims Act

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False Claims Act

The

Civil

FCA

protects the Government from being overcharged. No specific intent to defraud is required.

Filing false claims may result in fines of up to three times the programs' loss

plus $11,000 per claim filed. Under the Civil FCA, each instance of an item or a service billed to Medicare or Medicaid counts as a claim, so fines can add up quickly.

The Civil FCA contains a

whistleblower provision

that allows a private individual to file a lawsuit on behalf of the United States and entitles that

whistleblower

to a percentage of any recoveries. Whistleblowers could be current or ex-business partners, office staff, Members, or competitors.

The fact that a claim results from a kickback or is made in violation of the Stark law also may render it false or fraudulent, creating liability under the Civil FCA as well as the Anti-Kickback Statute or Stark law.

The Criminal FCA

penalties for submitting false claims include imprisonment and criminal fines. OIG also may impose administrative civil monetary penalties for false or fraudulent claims. Whistleblowers

A whistleblower is a person who exposes information or activity that is deemed illegal, dishonest, or violates professional or clinical standards. They are protected and rewarded.Protected: Persons who report false claims or bring legal actions to recover money paid on false claims are protected from retaliation. Rewarded: Persons who bring a successful whistleblower lawsuit receive at least 15 percent but not more than 30 percent of the money collected.

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It is illegal to submit claims for payment to Medicare or Medicaid that you know or should know are false or fraudulent

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Anti-Kickback Statute

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Anti-Kickback Statute

The AKS is a

Criminal

law that prohibits the knowing and willful payment of "

remuneration

" to induce or reward patient referrals or the generation of business involving any item or service payable by the Federal health care programs (e.g., transportation services for Medicare or Medicaid patients).

Remuneration

includes anything of value and can take many forms besides cash, such as free rent, expensive hotel stays and meals, and excessive compensation for medical directorships or consultancies. 

In some industries, it is acceptable to reward those who refer business to you. However, in the Federal health care programs,

paying for referrals is a crime

. 

The statute covers the

payers of kickbacks-those who offer or pay remuneration- as well as the recipients of kickbacks-those who solicit or receive remuneration.

Kickbacks in health care can lead to:

Overutilization - Increased program costs - Corruption of medical decision-making - Patient steering - Unfair CompetitionCriminal penalties and administrative sanctions for violating the AKS include fines, jail terms, and exclusion from participation in the Federal health care programs.

25ANTI-REFERRAL

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Stark Law

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Stark Law

The Stark Statute prohibits a physician from making referrals for certain designated health services to an entity when the physician (or a member of his or her family) has:

• An ownership/investment interest; or

• A compensation arrangement (Exceptions Apply)

For example, if you invest in an imaging center, the Stark law requires the resulting financial relationship to fit within an exception or you may not refer patients to the facility and the entity may not bill for the referred imaging services.

The Stark law is a

strict liability statute

, which means proof of specific intent to violate the law is not required. The Stark law prohibits the submission, or causing the submission, of claims in violation of the law's restrictions on referrals.

Penalties

Medicare claims tainted by an arrangement that does not comply with the Stark Statute are not payable. A penalty of around

$23,800

may be imposed for each service provided. There may also be around a

$159,000 fine for entering into an unlawful arrangement or scheme. Physicians can face exclusion from participation in the Federal health care programs as well.

27PHYSICIAN SELF-REFERRAL

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Healthcare and Criminal

Fraud

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Fraud Statute

“Whoever knowingly and willfully executes, or attempts to execute, a scheme to … defraud any health care benefit program … shall be fined … or imprisoned not more than 10 years, or both.”

Conviction under the statute does not require proof that the violator had knowledge of the law or specific intent to violate the law.

Examples

Louisiana Legislative Auditors identified over 55,000 claims costing over $1.6M with no corresponding Medicaid medical claims in 2015.

Guam Medical Transport submitted nearly $11M in claims for beneficiaries who didn’t qualify for the service. They coached Members to act less abled to provide them with higher modes of transportation and bill higher-priced codes. One of the owners was the head pastor at the local Church.

Dr.

Demoz

colluded with Majestic Transportation for 110,894 rides, or $3.4M in

Amublette

rides in 2009 - $900,000 more than the next transportation provider.

Criminal Fraud

Persons who knowingly make a false claim may be subject to: • Criminal fines up to $250,000;

• Imprisonment for up to 20 years; or • Both. If the violations resulted in death, the individual may be imprisoned for any term of years or for life.

29INTENTIONAL TAKING FROM THE GOVERNMENT HEALTHCARE PROGRAMS

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Civil Monetary Penalty

Law

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Civil Monetary Penalties

The Office of Inspector General may impose Civil penalties for a number of reasons, including:

• Arranging for services or items from an excluded individual or entity;

• Providing services or items while excluded;

• Failing to grant OIG timely access to records;

• Knowing of an overpayment and failing to report and return it;

• Making false claims; or

• Paying to influence referrals.

Penalties

The penalties can be around $15,000 to $70,000 depending on the specific violation. Violators are also subject to three times the amount:

• Claimed for each service or item; or

• Of remuneration offered, paid, solicited, or received.

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BIG TROUBLE

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Conflict of Interest

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Conflict of Interest

Employees have an obligation to conduct business within guidelines that prohibit

actual or potential

conflicts of interest.

An actual or potential conflict of interest occurs when an employee is in a position to influence a decision that may result in a personal gain for that employee, a friend, or for a relative as a result of CTS’ business dealings.

A conflict of interest occurs when an employee’s judgment is adversely affected. Disclosure and Reporting is crucial to safeguard all parties. Failure to disclose may result in disciplinary action; including termination of employment.

Examples:Personal gain

where an employee or his or her relative or friend has a significant ownership in a firm with which CTS does business

When an employee, relative, or friend

receives any kickback, bribe, gift, or special consideration

as a result of any transaction or business dealing involving CTS

33APPEARANCE AND PERCEPTION

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Code of Conduct

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Knowledge Base

Testing

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Hypothetical Situation

Issue Spotting

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Skills in Practice

A caller reaches ABC and requests information about their friend’s upcoming scheduled trip appointments. The CSR delivers the information, then the caller requests a trip of their own using their friend’s Medicaid ID number. The caller requests a certain driver, because that driver will take riders to the convenience store before going to the appointment. CSR does not give the caller that driver, instead the CSR secures the ride with their cousin who is a transportation provider with ABC and gives the CSR $50 for every trip they assign.

When the driver arrives to provide transport, they identify themselves as the transportation provider and they are at the arrival location within 15 minutes of pick up time. The driver assists the rider and their wheelchair in the vehicle, but there is not enough straps to secure the wheelchair facing forward and instead allow the wheelchair to face the van’s sliding door. Upon a stop, the wheelchair falls over in the van. The driver panics, stops the vehicle, and tries to jerk the wheelchair upright with the person inside. The rider calls ABC to report the fall and the CSR, understanding it is their cousin’s company, doesn’t report the accident to their team lead, provider relations, or compliance.

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WHATS WRONG WITH THE STORY BELOW

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A caller reaches ABC and requests information about their friend’s upcoming scheduled trip appointments. The CSR delivers the information, then the caller requests a trip of their own using their friend’s Medicaid ID number. The caller requests a certain driver, because that driver will take riders to the convenience store before going to the appointment. CSR does not give the caller that driver, instead the CSR secures the ride with their cousin who is a transportation provider with ABC and gives the CSR $50 for every trip they assign.

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ISSUES

Issues

Caller identity never verified (HIPAA Violation)

CSR gave out member information, an unauthorized HIPAA disclosure

CSR books a ride for the caller under another member’s ID number (Fraud)

Members cannot request a certain provider or driver

CSR has a conflict of interest with their family’s business

CSR is receiving payment for referrals (Anti-Kick Back)

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When the driver arrives to provide transport, they identify themselves as the transportation provider and they are at the arrival location within 15 minutes of pick up time. The driver assists the rider and their wheelchair in the vehicle, but there is not enough straps to secure the wheelchair facing forward and instead allow the wheelchair to face the van’s sliding door. Upon a stop, the wheelchair falls over in the van. The driver panics, stops the vehicle, and tries to jerk the wheelchair upright with the person inside. The rider calls ABC to report the fall and the CSR, understanding it is their cousin’s company, doesn’t report the accident to their team lead, provider relations, or compliance.

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Issues

Driver transported the rider without the appropriate securement

Driver injures the rider (Significant Event)

Driver doesn’t pull the vehicle over to the side of road, nor use emergency flashers, doesn’t call for assistance to help the passenger or ABC to report the accident

CSR at ABC did not report the Significant Event – ABC doesn’t report it to the Client and State timely

ISSUES

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Test Questions

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Knowledge Testing

Last month, while reviewing a monthly report from one of CTS’ Clients, you identified multiple enrollees for which the CTS is being paid, who are not enrolled in the plan. You spoke to your supervisor who said not to worry about it. This month, you have identified the same enrollees on the report again. What should you do?

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QUESTION 1

Select the correct answer

A. Decide not to worry about it as your supervisor instructed – you notified him last month and now it’s his responsibility

B. Although you have seen notices about the Sponsor’s non-retaliation policy, you are still nervous about reporting – to be safe, you submit a report through your compliance department’s anonymous tip line so you cannot be identified

C. Wait until the next month to see if the same enrollees appear on the report again, figuring it may take a few months for CMS to reconcile its records – if they are, then you will say something to your supervisor again

D. Contact law enforcement and CMS to report the discrepancy

E. Ask your supervisor about the discrepancy again

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Knowledge Testing

A Member Submitted a Friends and Family Reimbursement Claims Form requesting two things: 1) to back-date their trips date by one month outside the normal claims period, and 2) to use an address that is farther away than the address listed in our system. What should you do?

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QUESTION 2

Select the correct answer

A. Refuse to change the date or use the new address, but decide not to mention the request to a supervisor or the compliance department

B. Make the requested changes because the Members can determine claims dates and can change their address with CSRs at CTS

C. Tell the Member you will take care of it, but then process the Claims form properly (without the requested revisions) – you will not file a report because you don’t want the Member to complain or file a grievance against you

D. Process the Claims Form properly (without the requested revisions) – inform your supervisor and the compliance officer about the Member’s request

E. Contact law enforcement and the Centers for Medicare & Medicaid Services (CMS) to report the Member’s behavior

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Knowledge Testing

You discover an unattended email address or fax machine in your office that receives Member appeals requests. You suspect that no one is processing the appeals. What should you do?

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QUESTION 3

Select the correct answer

A. Contact law enforcement

B. Nothing

C. Contact your compliance department (via compliance hotline or other mechanism)

D. Wait to confirm someone is processing the appeals before taking further action

E. Contact your supervisor

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Knowledge Testing

You are in charge of payment of claims submitted from providers. You notice a

certain provider

has requested a substantial payment for a large number of members. Many of these claims are for a certain trip location. You review the same type of trips for other providers and realize that the

certain provider’s claims far exceed any other provider that you reviewed.What do you do?

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QUESTION 4

Select the correct answer

A. Call that

Certain Provider

and request additional information for the claims

B. Consult with your immediate supervisor for next stepsC. Contact the compliance department

D. Reject the claimsE. Pay the claims

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References

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References

Social Security Act:

Title 18 -

Code of Federal Regulations*:

42 CFR Parts 422 (Part C) and 423 (Part D)

* 42 C.F.R. §§ 422.503(b)(4)(vi) and 423.504(b)(4)(vi) - CMS Guidance:

Manuals, HPMS MemosOther Sources: OIG/DOJ (fraud, waste and abuse (FWA)), HHS (HIPAA privacy)

State Laws:

Licensure, Financial Solvency

CTS

https://www.ctstransit.com/

CMS

https://www.cms.gov/

Medicarehttps://www.medicare.gov/

Medicaidhttps://www.medicaid.gov/ - Go to the State Specific Health and Human Services for Medicaid Info on a Particular PlanCompliance Elements

https://oig.hhs.gov/compliance/provider-compliance-training/files/compliance101tips508.pdf HIPAAhttps://www.hhs.gov/hipaa/for-professionals/security/laws-regulations/index.html Office of Civil Rightshttps://www.hhs.gov/ocr/index.html

Exclusions

https://exclusions.oig.hhs.gov

https://www.sam.gov

http://www.gpo.gov/fdsys/pkg/USCODE-2013-title42/pdf/USCODE-2013-title42-chap7-subchapXI-partA-sec1320a-7.pdf

42 U.S.C. Section 1320a-7

http://www.gpo.gov/fdsys/pkg/CFR-2014-title42-vol5/pdf/CFR-2014-title42-vol5-sec1001-1901.pdf

42 Code of Federal Regulations Section 1001.1901

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References

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FWA

42 Code of Federal Regulations (CFR) Section 422.503(b)(4)(vi)(C);

42 CFR Section 423.504(b)(4)(vi)(C); Law

Available AtAnti-Kickback Statute 42 U.S.C. Section 1320A-7b(b)

http://www.gpo.gov/fdsys/pkg/USCODE-2013-title42/pdf/USCODE-2013-title42-chap7-subchapXI-partA-sec1320a-7b.pdf

Civil False Claims Act 31 U.S.C. Sections 3729–3733

http://www.gpo.gov/fdsys/pkg/USCODE-2013-title31/pdf/USCODE-2013-title31-subtitleIII-chap37-subchapIII.pdf

Civil Monetary Penalties Law 42 U.S.C. Section 1320a-7a

http://www.gpo.gov/fdsys/pkg/USCODE-2013-title42/pdf/USCODE-2013-title42-chap7-subchapXI-partA-sec1320a-7a.pdf

Criminal False Claims Act 18 U.S.C. Section 287

http://www.gpo.gov/fdsys/pkg/USCODE-2013-title18/pdf/USCODE-2013-title18-partI-chap15-sec287.pdf

Exclusion 42 U.S.C. Section 1320a-7http://www.gpo.gov/fdsys/pkg/USCODE-2013-title42/pdf/USCODE-2013-title42-chap7-subchapXI-partA-sec1320a-7.pdfHealth Care Fraud Statute 18 U.S.C. Section 1347

http://www.gpo.gov/fdsys/pkg/USCODE-2013-title18/pdf/USCODE-2013-title18-partI-chap63-sec1347.pdfPhysician Self-Referral Law 42 U.S.C. Section 1395nn http://www.gpo.gov/fdsys/pkg/USCODE-2013-title42/pdf/USCODE-2013-title42-chap7-subchapXVIII-partE-sec1395nn.pdf

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References

HYPERLINK URL

LINKED TEXT/IMAGE

MLN Educational Products https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts

MLN

Matters

® Articles

https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles

MLN Connects® National Provider Calls

https://www.cms.gov/Outreach-and-Education/Outreach/NPC

MLN Connects® Provider Association Partnerships https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLN-Partnership

MLN Connects® Provider eNews

https://www.cms.gov/Outreach-and-Education/Outreach/FFSProvPartProgProvider electronic mailing lists https://www.cms.gov/Outreach-and-Education/Medicare-Learning-NetworkMLN/MLNProducts/Downloads/MailingLists_FactSheet.pdfMedicare Managed Care Manual

https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/mc86c21.pdf

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References

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