Fraud and Abuse Waivers
ACO Pre-Participation Waiver:
The following information describes each arrangement for which our ACO seeks protection under the ACO Pre-Participation Waiver, including any material amendment or modification to a disclosed arrangement.
Application and Operational Services:
- Parties to the arrangement: ACO, ACO participants, ACO providers/suppliers, and vendors providing services to the ACO, ACO participants and/or ACO providers/suppliers.
- Date of arrangement: As of January 1, 2015.
- Items, services, goods or facility provided: The ACO entered into an arrangement pursuant to which Hattiesburg Clinic, PA (an ACO participant) provided all funding for the administrative services, management services, and information technology necessary to apply for, and successfully participate in, the MSSP and the ACO Investment Model (“AIM”). Under this arrangement the ACO participants agreed to participate in the ACO and MSSP, provide in-kind services to and for the ACO and other ACO participants, and assign their interest in the AIM funding to the ACO and Hattiesburg Clinic, PA. This arrangement included the formation and capitalization of the ACO, and the development of the ACO operating agreement and participation agreements.
- Date and nature of any amendments to the arrangement, if applicable: None.
ACO Participation Waiver:
The following information describes each arrangement for which our ACO seeks protection under the ACO Participation Waiver, including any material amendment or modification to a disclosed arrangement.
Operational Services:
- Parties to the arrangement: ACO, ACO participants, ACO providers/suppliers, and vendors providing services to the ACO, ACO participants and/or ACO providers/suppliers.
- Date of arrangement: January 1, 2016.
- Items, services, goods or facility provided: The ACO entered into an arrangement pursuant to which Hattiesburg Clinic, PA (an ACO participant) provides funding for the administrative services, management services, and information technology necessary to successfully participate in the MSSP and AIM. Under this arrangement the ACO participants participate in the ACO and MSSP, provide in-kind services to and for the ACO and other ACO participants, and assign their interest in the AIM funding to the ACO and Hattiesburg Clinic, PA. This arrangement includes the respective obligations of the ACO, ACO participants, and ACO providers/suppliers under the terms of the ACO’s participation agreement with the ACO participants. This arrangement also includes the respective obligations of the ACO and Hattiesburg Clinic, PA under the terms of the ACO’s operating agreement.
- Date and nature of any amendments to the arrangement, if applicable: As of January 1, 2019, neither AIM nor AIM funding are available to the ACO or the ACO participants.
Provision of Medical Equipment:
- Parties to the arrangement: ACO, ACO participants, ACO providers/suppliers, and Medicare beneficiaries attributed to the ACO by CMS.
- Date of arrangement: February 18, 2016.
- Items, services, goods or facility provided: Under this arrangement the ACO, ACO participants, or ACO provider/suppliers may provide to Medicare beneficiaries attributed to the ACO, for free or below fair market value, medical equipment that the ACO, ACO participant, or ACO provider/supplier has determined is necessary or useful for the patient to fully engage in preventive care, or to adhere to his/her treatment, drug or follow-up care regime or to manage his/her chronic disease or condition.
- Date and nature of any amendments to the arrangement, if applicable: None.
Provision of Delivery Services and Medications:
- Parties to the arrangement: ACO, ACO participants, ACO providers/suppliers, and Medicare beneficiaries attributed to the ACO by CMS.
- Date of arrangement: February 18, 2016.
- Items, services, goods or facility provided: Under this arrangement the ACO, ACO participants, or ACO provider/suppliers may provide to Medicare beneficiaries attributed to the ACO: (i) free or discounted (below fair market value) delivery of medications, or (ii) free medications to such beneficiaries with demonstrated financial need. Such items and services may be provided when the ACO, ACO participant, or ACO provider/supplier has determined that such service or medication is necessary or useful for the patient to fully engage in preventive care, or to adhere to his/her treatment, drug or follow-up care regime, or to manage his/her chronic disease or condition.
- Date and nature of any amendments to the arrangement, if applicable: None.
Transportation Services:
- Parties to the arrangement: ACO, ACO participants, ACO providers/suppliers, and Medicare beneficiaries attributed to the ACO by CMS.
- Date of arrangement: February 18, 2016.
- Items, services, goods or facility provided: Under this arrangement, the ACO, ACO participants, or ACO provider/suppliers may provide affordable transportation options to Medicare beneficiaries attributed to the ACO. Such transportation services include the provision of shuttle services, or a coupon or voucher that such beneficiaries can use to purchase transportation services from a transportation vendor. The transportation services are provided so that the beneficiaries can keep their appointments with their primary care providers, and obtain medications and other necessary medical items and services.
- Date and nature of any amendments to the arrangement, if applicable: None.
Care Management Services:
- Parties to the arrangement: ACO, ACO participants, and ACO providers/suppliers.
- Date of arrangement: January 1, 2020.
- Items, services, goods or facility provided: Under this arrangement Hattiesburg Clinic, PA (an ACO participant) provides care management services to other ACO participants and to ACO providers/suppliers. Such care management services include the provision care management personnel (e.g.: care coordinators and care managers), and care management policies and procedures.
- Date and nature of any amendments to the arrangement, if applicable: None.
