Annual Provider Training & Compliance Attestation

Please review and agree to the following requirements. Non-compliance may result in corrective action, retraining, or termination of your Provider contract. If applicable, you are responsible for ensuring contracted, delegated, downstream, affiliated, and subcontracted entities comply with applicable requirements.

Providers, groups, facilities, delegated entities, and other contracted Organizations participating in one or more Peak Health lines of business must comply with applicable federal and state laws, regulations, contractual obligations, provider manual requirements, accreditation standards, and Peak Health policies. For purposes of this attestation, "Organization" means the provider, provider group, facility, delegated entity, vendor, or other contracted entity executing this attestation. This attestation documents compliance with applicable requirements and should be completed for all Peak Health products in which the Organization participates. Once submitted, your record will reflect compliance with the applicable annual attestation requirements.

The attestation applies to your contract with Peak Health and includes general requirements applicable to all providers, as well as additional requirements for the Peak Health lines of business in which you participate:
• Medicare Advantage PPO1 (MA): Providers participating in Peak Health Medicare Advantage products are required to comply with applicable CMS requirements.
• Dual Eligible Special Needs Plans2 (DSNP): Providers participating in Peak Health DSNP products are required to comply with applicable CMS requirements and SNP Model of Care (MOC) requirements.
• Marketplace / Exchange Plans: Providers participating in Peak Health Individual ACA Plans products are required to comply with applicable federal and state Marketplace requirements, contractual obligations, provider manual requirements, accreditation requirements, and Peak Health policies.
• Commercial Products: Providers participating in Peak Health Commercial products are required to comply with applicable federal and state laws, contractual obligations, provider manual requirements, and Peak Health policies.

 

1 Medicare Advantage: Medicare-approved plan from a private company that offers an alternative to Original Medicare for health and drug coverage.
2 Dual Eligible Special Needs Plans (DSNPs): Plans that enroll individuals who are entitled to both Medicare (title XVIII) and medical assistance from a state plan under Medicaid (title XIX).

Organizations participating in any Peak Health line of business must:
• Comply with all applicable federal and state laws, regulations, contractual obligations, accreditation standards, provider manual requirements, Peak Health policies, standards of conduct, and other requirements associated with the products in which the Organization participates, including the applicable Peak Health Provider Manual and Peak Health Code of Ethical Conduct, and maintain and distribute such policies, procedures, and standards of conduct as applicable to the services provided under the Organization's agreement with Peak Health.
• Maintain all licenses, certifications, registrations, credentials, demographic information, participation information, and provider directory information required to participate in applicable programs and product lines and promptly report changes necessary to support provider directory accuracy, network adequacy, regulatory reporting, and other Peak Health requirements.
• Retain records and documentation necessary to support compliance with applicable requirements and provide timely access to such records upon request.
• Screen employees, providers, contractors, subcontractors, delegated entities, and downstream entities, as applicable, for conflicts of interest, sanctions, and exclusions and notify Peak Health within one (1) business day of any status changes that may affect participation in Peak Health products.
• Cooperate with audits, investigations, monitoring activities, compliance reviews, corrective action activities, and requests for records conducted by Peak Health or authorized governmental agencies.
• Report suspected fraud, waste, abuse, compliance concerns, licensure restrictions, adverse regulatory actions, ownership changes, practice closures, delegated entity issues, and other events that may affect participation in Peak Health products.
• Ensure that contracted, delegated, affiliated, downstream, and subcontracted entities comply with applicable requirements.
• Provide services in accordance with applicable nondiscrimination, accessibility, cultural competency, health equity, and language assistance requirements.
• Establish and maintain business continuity and contingency plans designed to support continuation of critical services during emergencies, disasters, or system disruptions.

Organizations participating in Peak Health MA and/or DSNP products must comply with all applicable federal and state laws, regulations, contractual obligations, provider manual requirements, and Centers for Medicare & Medicaid Services (CMS) requirements, including requirements applicable to First Tier, Downstream, and Related Entities (FDRs). The Organization further attests that it has established and maintains the controls, policies, procedures, standards of conduct, training, reporting mechanisms, and oversight processes necessary to support compliance with applicable CMS requirements, including 42 C.F.R. §§ 422.503 and 423.504,  MS guidance set forth in Chapter 21 of the Medicare Managed Care Manual and  Chapter 9 of the Medicare Prescription Drug Benefit Manual, and any applicable state requirements governing DSNP products. The Organization shall maintain  documentation supporting compliance with the below requirements for a minimum of ten (10) years and provide such documentation to Peak Health upon request: 

1. Organization assumes responsibility for maintaining compliance materials, training, policies, procedures, and codes of conduct that satisfy applicable CMS requirements. For your reference, Peak Health has listed below the following resources. Organization may utilize Peak Health materials, substantially similar internal materials, or a combination thereof, provided such materials satisfy applicable CMS requirements.

• Peak: Fraud Waste & Abuse Training_PHH_25 | Review 360
• Medicare Essentials and CMS Plan Contractor PHH
• Peak Model of Care (MOC) Training
• Peak Health Code of Ethical Conduct
• Peak Health Medicare Compliance Program
• Cultural Competency and Language Assistance
• 2026 Peak Health Provider Manual

Organization distributes compliance policies, procedures, and standards of conduct, including conflict of interest provisions, and ensures employees supporting Peak Health Medicare business complete required General Compliance and Fraud, Waste, and Abuse (FWA) training within 90 days of hire or contracting, upon updates, and annually thereafter.

2. Report compliance concerns and suspected, or actual violations related to the Medicare program to Peak Health. The Organization trains its employees in Peak Health’s reporting process outlined in the Peak Health Provider Manual.
3. Documents its screening of the DHHS OIG List of Excluded Individuals and Entities (LEIE list) and the SAM.GOV exclusion list prior to the hiring or contracting, and monthly thereafter for employees and Downstream Entities. The Organization will immediately notify Peak Health and remove any person or entity from working on Peak Health Medicare business.
4. Does not engage in offshore operations for Peak Health that uses beneficiary protected health information (PHI). The Organization will notify Peak Health of any changes. Offshore refers to any country or territory that is not one of the fifty (50) United States or a United States territory.
5. Creates a plan to keep any critical services running during disruptions like system outages, natural disasters, or other emergencies. The plan is reviewed and updated regularly, and staff are trained on what to do.
6. Ensures that all employees and providers supporting Peak Health’s DSNP complete Model of Care (MOC) training as required by CMS regulations (42 CFR §422.101(f)(2)(ii)) and Peak Health standards and NCQA requirements. Training covers the four core MOC elements: SNP population, care coordination, provider network responsibilities, and quality measurement. Documentation of completion is maintained.
7. The Organization has systems and processes in place for monitoring its Downstream Entities relating to Medicare Compliance Program requirements.

 

Organizations participating in Peak Health Commercial and/or Marketplace/Exchange products must comply with all applicable federal and state laws, regulations, contractual obligations, provider manual requirements, accreditation standards, and Peak Health policies applicable to the products in which they participate.
Organizations participating in Marketplace/Exchange products must also comply with applicable Marketplace and Exchange requirements, including applicable provisions of 45 CFR Parts 92, 155, and 156. The Organization shall cooperate with Peak Health's quality, accreditation, provider directory, and regulatory compliance activities, including activities that support NCQA accreditation. These requirements apply to services performed for Peak Health Marketplace and Exchange products and, where applicable, must also be satisfied by delegated or contracted entities engaged by the Organization.

I certify that I am an authorized representative of my Organization and that the statements made in this attestation are true and correct to the best of my knowledge. I further certify that my Organization has reviewed and complies with all applicable requirements set forth in this attestation for each Peak Health line of business in which the Organization participates and for all applicable Tax Identification Numbers (TINs) covered by this attestation. My Organization agrees to maintain documentation supporting the statements made in this attestation in accordance with applicable laws, regulations, accreditation standards, contractual obligations, and our agreement with Peak Health and will provide such documentation upon request. My Organization understands that failure to maintain or produce supporting documentation may result in corrective action, a corrective action plan, or other contractual remedies, including contract termination.