Harvard Pilgrim Health Care’s Medicare Compliance Program
As a Medicare Advantage plan, Harvard Pilgrim Health Care is committed to complying with all rules and regulations set forth by the Centers for Medicare & Medicaid Services (CMS). Many of these guidelines also apply to our business partners, including agents and brokers. As a subcontracted agent/broker supporting our Medicare Advantage product, you are required to comply with many of the same rules and regulations governing the Medicare Advantage and Part D programs, including the need for developing and implementing a comprehensive and effective compliance program.
Harvard Pilgrim maintains a corporate-wide Code of Conduct that outlines the values and standards that guide our business practices and day-to-day actions. As part of our comprehensive Medicare Compliance Program, we have created Medicare Standards of Conduct to assist our business partners in understanding how Harvard Pilgrim does business and outline your responsibilities as a business partner who provides services to Harvard Pilgrim and/or our members. Please review our Medicare Standards of Conduct for First Tier, Downstream and Related Entities (FDRs) and share it with the appropriate employees.
These standards are not intended to replace provisions contained in any agreement you have with Harvard Pilgrim and/or its subsidiaries. In the event of any inconsistency between these standards and the terms of your agreement with Harvard Pilgrim and/or its subsidiaries, the terms of the agreement shall prevail.