A Quarterly Guide to FDR Compliance

2020 Kickoff Anthem’s First-tier, Downstream and Related Entities

Anthem’s 2020 Medicare FDR Oversight Kickoff

Helpful Compliance Links…

To review regulatory references to monitoring requirements:

CMS Medicare Managed Care Manual Ch. 11

Medicare Managed Care Manual Ch. 21 & Prescription Drug Benefit Manual Ch. 9

Important Numbers:• Fraud Hotline:

1-866-847-8247• Ethics & Compliance Helpline:

1-877-725-2702

Welcome to Anthem’s 2020 Medicare First-tier, Downstream and Related entities(FDR) oversight kickoff! With a new year upon us, the Medicare FDR OversightTeam wants to ensure you have all the necessary tools and documents to make2020 a success for FDR oversight. Below you will find a description of thedocumentation and tools included in our 2020 Kickoff packet. If you have anyquestions regarding this information, please reach out to us atFDRSharedMailbox@anthem.com. We hope you have a great 2020!

Compliance is everyone’s responsibility and it is Anthem’s job to communicate thiscritical message to our FDRs. We want to ensure everyone supporting AnthemMedicare members is aware of both our general principles and values when itcomes to conducting business, as well as the more detailed policies regarding ourMedicare Compliance Program. One of the ways we communicate this message isthrough Anthem’s Standards of Ethical Business Conduct (SOEBC) and Anthem’sEthics and Compliance Plan.

• The SOEBC provides guidance on Anthem’s commitment to uphold itsprinciples and the expectation that its FDRs likewise conduct business in anethical and compliant manner.

• The Ethics & Compliance Plan with Medicare Addendum sets forth theprinciples along with policies and procedures outlining how Anthem’sassociates, and our FDRs, are required to conduct business and themselves.Anthem’s Ethics & Compliance Plan supports a culture of ethics andcompliance and continuous improvement through an infrastructure thateffectively prevents, detects and resolves issues and noncompliantconduct. It provides the knowledge and tools associates need to performtheir jobs in a compliant manner, identify potential compliance issues, andreport suspected or known non-compliance as well as fraud, waste andabuse. The Medicare Compliance Plan Addendum attached to the Ethics &Compliance Plan provides additional detail and requirements specific toAnthem’s Medicare business.

While it is Anthem’s responsibility to communicate compliance expectations toour FDRs, it is the responsibility of our FDRs to ensure this information is providedto their employees. FDRs must use Anthem’s SOEBC and Ethics & Compliance Planwith Medicare Addendum to ensure employees are aware of complianceexpectations and requirements. As an alternative, FDRs may instead choose to usecomparable standards of conduct and compliance policies of their own.

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FDR Newsletter

Anthem’s Standards of Ethical Business Conduct & Ethics and Compliance Plan with Medicare Addendum

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Whether using Anthem’s materials or the FDR’s own information, the standards of conduct and compliance policiesmust be distributed to FDR employees who support Anthem’s Medicare business. Distribution must occur:

• within 90 days of hire (or contracting)• annually thereafter; and• when there are updates.

FDRs may choose to distribute (or make available) this information in the most effective way for their organization.However, FDRs must maintain documentation to evidence standards of conduct and compliance policies weredistributed (or made available) to employees. Examples of acceptable documentation include employee attestations(confirming receipt), emails showing documents were sent to all employees, or a screenshot of the company intranetsite linking employees to standards of conduct/policies.

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Anthem’s FDR Oversight Team wants to ensure our FDRs have the information and tools needed to succeed inimplementing and demonstrating an effective compliance program, and for participating in Anthem’s Medicare FDROversight Program. We have created a helpful tool kit containing the following information and tools:

FDR Oversight Program Overview – This information provides FDRs with a high-level overview of Anthem’s FDROversight Program. Among the areas of concern it explains the regulatory requirements behind the OversightProgram, Anthem’s processes to maintain oversight of our FDRs, and the several methods for reporting acompliance and/or FWA Issue to Anthem.

Overview of FDR Compliance Requirements – Includes the CMS requirements by which FDRs participating inMedicare Advantage must comply.

Policy and Procedure Templates – To assist our FDRs in ensuring they have proper policies and proceduresdocumented and implemented in 2020, we are providing sample templates for your review and/or adaptation.

FDR Oversight - Tools You Can Use!

2020 CMS Offshore Attestation: If an FDR is located offshore (or contracts with a subcontractor located offshore)and who has access to Anthem’s Medicare Protected Health Information (PHI), it must submit an OffshoreAttestation to Anthem within 30-days from contract execution or whenever changes are made to the contract. Wehave included a copy for your reference.

OIG/GSA Exclusion Screening Tips and Reminders – Based on the latest CMS Compliance Program EffectivenessAudit Findings, CMS federal exclusion screenings ranks as the #1 requirement with the highest failure percentage.This tip sheet will help FDRs ensure they have proper Federal Exclusion Screening processes in place. It providersreminders on what is required for screenings, which associates need to be screened and what supportingdocumentation must be maintained by FDRs to evidence compliance.

FDR Disciplinary Actions Information Form – This form is intended to solicit additional detail regarding disciplinaryactions received by the FDR or FDR employees for violations of standards of conduct, non-compliance withMedicare requirements and/or incidents of FWA as reported on the FDR Annual Monitoring Survey.

Anthem Methods of Reporting Compliance/FWA Issues – This document serves as a helpful tip sheet on thedifferent methods for reporting a compliance and/or FWA issue to Anthem.

Medicare Regulatory Exhibit (MRE) – All FDRs contracted to support Anthem’s Medicare business are required tohave an executed MRE as part of their contract. We have included a copy for your reference.

OIG & GSA Exclusion Screening Tracker Template – This tool can be used by FDRs for tracking the required pre-hireand monthly employee screenings against the OIG and GSA exclusion listings. Please note – the tracker is a helpfultool; however, FDRs must also maintain supporting documentation to include screenshots from the OIG and GSAwebsites showing the results of the employee search, or output reports from a third-party vendor or designated areaconducting the screenings.

Ariba System Information & Tips – This section provides useful and helpful tips on the Ariba System, which is usedby Anthem to issue the annual FDR Monitoring Survey. FDRs utilize the Ariba System (as do the Anthem businessowners) to respond to and submit documentation during the Annual FDR Monitoring Survey process.

Contract List- This is a listing of all Anthem’s contract numbers in 2020. Please refer to this list when confirmingwhich product the FDR supports.

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Anthem FDR Oversight Monitoring Survey – Let’s Review!

Anthem’s FDR Oversight Program maintains compliance-focused oversight of Anthem’s FDRs through annual monitoring and focused audits to ensure CMS FDR program requirements are met. To prepare our FDRs for the upcoming Calendar Year 2020 monitoring cycle let’s review the Monitoring Survey Sections and the requirements that will be validated by our team:

FDR Point of Contact and Compliance Officer Information Ensure you maintain your organization’s point of contact and Compliance Officer Information up to date in

order to maintain accurate lines of communication that will promote a smooth audit cycle. In the event of any designee changes please email our FDR Shared Mailbox at FDRSharedMailbox@anthem.com.

Locations You will be required to identify the total number of office locations/facilities where Medicare functions are

performed on behalf of Anthem. FDRs located in a CMS Hot-Spot will be required to identify additional measures implemented to prevent

privacy/security breaches from occurring for each 'hot spot' location.• Offshore

Anthem is required to disclose to CMS any services under agreement that are performed offshore by Supplier/Vendor or any of Vendor’s subcontractors or Downstream Entities. Therefore, FDRs shall immediately notify Anthem of any services that are being contemplated to be performed offshore to allow Anthem to complete the CMS required Offshore Attestation to CMS as required.

Code of Conduct / Compliance Policies/ Fraud Waste and Abuse Education Ensure Anthem’s Standards of Ethical Business Conduct (SOEBC) or FDR’s own Standards of Conduct,

Compliance Policies and Procedures and Fraud Waste and Abuse (FWA) education/training documents are distributed to FDR’s employees supporting Medicare Anthem Business within the required timeframes (within 90-days from hire date, annually thereafter or when material updates are made to the document).

FDRs must be able to demonstrate compliance by providing supporting evidence of Standards of Conduct being distributed and acknowledged by the staff supporting Anthem’s Medicare Anthem Business.

• Reporting Compliance and/or Fraud, Waste and Abuse A key factor in Anthem’s Compliance Program is open communication between the Medicare Compliance

Officer and Associates, FDRs, the Board, members of the Compliance Committee, the Chief Compliance Officer and the Senior Leadership Team (SLT).

Anthem takes compliance concerns and suspected or actual violations related to the Medicare Program very serious. Anthem’s FDRs must ensure that all employees supporting Medicare Anthem Business are informed of how to report compliance concerns and suspected misconduct.

• Office of Inspector General (OIG)/GSA Federal Exclusion Verifications In our role as a government health care program contractor, Anthem may not employee or contract with

individuals or companies that are barred from taking part in, or receiving funds from the Medicare Program. To meet this obligation, we screen our associates, providers vendors against exclusion lists kept by the Office of Inspector General (OIG) AND General Services Administration (GSA/SAM) before hiring or entering into contracts, and monthly thereafter.

FDRs are required to screen against OIG and GSA exclusion lists in the same manner, and will be asked as part of Anthem’s FDR Oversight Monitoring to document and retain evidence of the exclusion screening verifications.

FDRs are required to remove immediately any employee or affiliate supporting Medicare Anthem Business from work whose name(s) turn up in the exclusion lists checks and to notify Anthem if such occurs.

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Record Retention FDRs must comply with Medicare laws, regulations, CMS instructions and agree to audits and

inspection by CMS and/or its designees and to cooperate, assist, provide information as requested, and maintain records for a minimum of 10 years.

FDRs must retain the documentation in a logical and organized manner for accessibility during a CMS or Anthem Audit for a period of minimum 10 years.

FDRs will be required to provide evidence of appropriate record retention policies and procedures. Monitoring of Downstream Entities

Anthem is responsible for the lawful and compliance administration of the Medicare Part C and D benefits under their contract with CMS, regardless whether Anthem has delegated any functions to FDRs.

FDRs are required to monitor compliance of the entities with which they contract to support Anthem Medicare Business. These entities are “downstream” entities of Anthem.

FDRs are responsible for the compliance of Anthem’s downstream entities. FDRs are required to provide evidence of having a procedure for monitoring downstream entities on a

regular basis. Downstream entities are required as well to provide supporting evidence of compliance with all CMS

requirements.

Questions? Please send us an email: FDRSharedMailbox@anthem.com

How to Report Compliance and/or Fraud, Waste

and Abuse (FWA) Issues

There are several ways to report violations: • Anthem’s Ethics and Compliance Helpline: 1-877-725-2702• Anthem’s Ethics and Compliance online tool: www.anthemethicshelpline.com• Ethics & Compliance E-mail box: ethicsandcompliance@anthem.com• Send a letter to: Post Office Box 791

Indianapolis, IN 46206• You may report an issue to your Anthem contact (Business Owner) or directly to:

Michelle Turano, Medicare Compliance Officer Michelle.Turano@anthem.com, (813) 830-6984 Michelle Nader, Chief Ethics Officer Michelle.Nader@anthem.com, (513) 336-2703

* Anthem enforces a strict policy of non-retaliation. Retaliation against anyone who reports compliance issue in good faith is strictly prohibited, including reports made by contracted vendors (FDRs). If you see retaliation or believe it has

occurred, you must report it.