Ascension Living PACE is a PACE Medicare Health Plan and a Part D Prescription Drug Plan. As such, PACE must adhere to CMS requirements of a Medicare Health Plan with few exceptions. Ascension Living PACE Compliance and Fraud Waste and Abuse Program describes the plan to ensure compliance with CMS requirements. Part of that plan is to ensure partnering entities of Ascension Living PACE adhere to CMS compliance requirements.
As a Medicare Health Plan, Ascension Living PACE partners with individuals and organizations in support of providing the most robust and efficient services. Partnering entities are referred to as First Tier, Downstream and Related Entities by CMS. Partnerships are defined through contractual arrangements. It is the responsibility of Ascension Living PACE to ensure that its contracting partners are committed to CMS compliance fulfillment including:
- Reducing fraud, waste and abuse (FWA)
- Complying with laws and regulations
- Implementing compliance policies
Compliance Fulfillment refers to adherence to CMS compliance and fraud waste and abuse (FWA) requirements found in Chapter 21 of the Medicare Managed Care Manual and Chapter 9 of the Prescription Drug Benefit Manual. These manuals reference the Code of Federal Regulations describing FDR compliance and FWA requirements. These requirements are discussed in the FDR Compliance Guide. It is the responsibility of the Medicare Health Plan to ensure First Tier Entities and their downstream contractors adhere to referenced CMS regulations. Please review the resources below and complete the provider attestation: