Our Commitment to Compliance
At HCP, we demonstrate our commitment to integrity and continuous compliance with legal and regulatory requirements through our business operations. To facilitate the delivery of the highest quality care to your patients, we strive to further demonstrate this commitment by providing guiding principles for ethical conduct to:
- Our provider network
- First-tier, downstream or related entities (FDRs)
- Our Workforce
Code of Conduct & Corporate Compliance Program
Our Code of Conduct and Corporate Compliance Program collectively outlines expected standards of conduct for our Workforce, providers, and FDR partners. They also provide the framework for compliance with state and federal laws established to prevent, detect and correct healthcare fraud, waste, abuse, and other non-compliant behavior.
Conflict of Interest and the Acceptance of Gifts Policy
Our Conflict of Interest and the Acceptance of Gifts Policy provides guidance for the acceptance of gifts from vendors and patients and for recognizing and avoiding situations that may present a conflict of interest (COI). All HCP providers are expected to read, understand and comply with this policy. As an HCP Provider, you are also required to complete the COI Disclosure Form provided in your re-credentialing package during the process or whenever a potential COI may arise.
Training & Education
HCP ensures that our providers and FDRs meet the Centers for Medicare and Medicaid Services (CMS) regulations by providing access to required general compliance and/or Fraud, Waste, and Abuse (FWA) Training, in accordance with 42 CFR § 422.503 and 42 CFR § 422.504. Other training modules are required in accordance with the Health Insurance Portability and Accountability Act (HIPAA), privacy and security, and other compliance-related regulations.
Annual HCP Direct Provider Training Modules (Required)*
- You may complete the following courses online by clicking on the course link below, or
- You may complete your own organization’s comparable training and select this option in the Provider & FDR Compliance Attestation.
Provider & FDR Compliance Attestation (Required)
You must submit the online “Attestation of Compliance” following completion of the required training upon credentialing or contracting and annually thereafter. HCP will notify you each year when your annual Attestation is due. You will be prompted to affirm your compliance with HCP’s and CMS’s training requirements in addition to Federal and State Medicaid exclusion screening requirements.
To access and complete, use this form:
Special Needs Plan (SNP) Model of Care (MOC) Provider Training
All EmblemHealth Medicare providers are required to complete the Special Needs Plan (SNP) Model of Care (MOC) training for each of the dual-eligible SNPs in which they participate, as mandated by the Centers for Medicare & Medicaid Services (CMS).
To satisfy this requirement, providers must complete the 2022 EmblemHealth SNP MOC training. The deadline to submit the applicable attestation was September 15, 2022. If you have not yet met this requirement to date, visit the EmblemHealth Learning Online webpage to complete the training and submit the attestation, or for additional information.
NYDOH Required Medicaid Cultural Health Training
Each year, the New York State Department of Health (NYDOH) requires all Medicaid healthcare professionals to complete cultural competency training for all staff who have regular and substantial contact with our members. This includes healthcare providers, administrators, and executives.
The training will provide you with an overview of your patients’ potential cultural, health literacy, and language needs and offers two tracks: one tailored for healthcare administrators and the other for healthcare providers (or those providing direct care and services).
To satisfy this training requirement, providers and their staff must complete The Guide to Providing Effective Communication and Language Assistance Services by October 1, 2023.
If you and your staff have already completed the training with another managed care plan, you are not required to complete the training again.
HIPAA Security & Privacy
Compliance with the provisions of the Health Insurance Portability and Accountability Act (HIPAA) is one of our top priorities. We are dedicated to maintaining the security and privacy of our members’ information. We provide training to our Workforce, provider network, and FDRs in accordance with our obligations under the HIPAA Privacy Rule and HIPAA Security Rule and to ensure proper access, use, and/or disclosure of protected health information.
Reporting Fraud, Waste, and Abuse
HCP has established a confidential hotline that enables employees, providers, patients, vendors, and other parties to report illegal conduct, compliance concerns, privacy issues, and other activity that might be a violation of HCP’s policies and healthcare-related regulations.
Call: (888) 475 – 8376. Available 24 hours per day, 7 days a week; multiple languages.
Online: Click here to submit a report
You may remain anonymous when submitting reports by phone and online.
Whistleblower & Non-Retaliation Policy
HCP’s Whistleblower & Non-Retaliation Policy prohibits intimidation or retaliation against anyone who reports a compliance concern in good faith.