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Compliance Program

iCare Compliance

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Independent Care Health Plan (iCare) is committed to ethical behavior and full compliance with all laws and regulations that apply to our health care business. To demonstrate iCare’s commitment to the highest standards of integrity and business ethics, as well as compliance with all Medicare and Medicaid program requirements, we have implemented a formal compliance program.

As an FDR (First Tier, Downstream and Related Entities) of Independent Care Health Plan, providing administrative or health care services related to our Medicare contract, you play a key role in the success of Independent Care Health Plan’s compliance program.

Frequenty Asked Questions and Program Requirements

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What do I need to do?
  • Distribute Independent Care Health Plan’s Compliance Program Materials (Code of Conduct and policies) or your own comparable materials to all employees and subcontractors providing services related to your iCare contract within 90 days of hire and annually thereafter.
  • Provide Fraud, Waste, and Abuse training or your own comparable training to all employees and subcontractors providing services related to your iCare contract within 90 days of hire and annually thereafter (unless deemed)
  • Screen all employees and subcontractors against the OIG and GSA exclusions databases.
  • Receive an attestation from any subcontractors performing services related to your iCare contract that they have met these requirements.
  • Retain all materials and documentation related to these compliance program requirements for 10 years.
  • Sign and submit your FDR Compliance Attestations to Independent Care Health Plan, if requested

Please see below for additional details on FDR compliance program requirements and resources.

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FDR Compliance Program Requirements
  • Distribute compliance policies and procedures and standards of conduct to all employees and applicable subcontractors within 90 days of hire and annually thereafter
  • Provide Fraud, Waste, and Abuse training meeting CMS requirements to all employees and applicable subcontractors within 90 days of hire and annually thereafter, unless deemed (see additional details below)
  • Screen all employees (permanent/temporary/intern) and subcontractors against the Office of the Inspector General (OIG) and General Services Administration (GSA) Exclusion Lists prior to hire and monthly thereafter
  • Ensure any contracted entities performing delegated functions related to iCare’s Medicare contract comply with all requirements
  • Retain materials and documentation related to compliance program requirements for 10 years

To help ensure we are all doing our part to prevent, detect, and correct FWA and Medicare noncompliance, and best serve our beneficiaries, all required materials are provided to you for use.

FDRs may also attest to meeting requirements using their own compliance materials, as long as they meet the CMS requirements and can be made available upon request for auditing and monitoring purposes.

To assist us in our required compliance program oversight, we ask you to complete an annual Medicare FDR Compliance Attestation and return it to us through one of the following methods:

  • Email:
  • Fax: 414-231-1092
  • Mail: Independent Care Health Plan
    • Attention: Compliance Dept./FDR Oversight
    • 1555 N. RiverCenter Drive, Suite 206
    • Milwaukee, WI 53212

Additional information regarding compliance program requirements and resources are outlined in the next section.

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Policies & Procedures and Standards of Conduct

At minimum, policies and procedures and/or Standards of Conduct must accomplish the following:

  • Articulate commitment to comply with all applicable Federal and State Standards
  • Describe compliance expectations as embodied in the Standards of Conduct
  • Provide guidance on dealing with suspected, detected, or reported compliance issues
  • Identify how to communicate compliance issues to appropriate compliance personnel
  • Describe how suspected, detected or reported compliance issues are investigated and resolved
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Fraud, Waste & Abuse Training

To reduce the potential burden on FDRs, CMS has developed and provided a standardized FWA training and education module. The module is provided under the program materials and also available through the CMS Medicare Learning Network (MLN) linked in additional resources below. It is not mandatory to use this training module, as long as the module in use meets all CSM requirements and can be made available upon request for auditing and monitoring purposes.

FDRs who have met the FWA certification requirements through enrollment into Parts A or B of the Medicare program or through accreditation as a supplier of DMEPOS are deemed to have met the FWA training and education requirements. No additional documentation beyond the documentation necessary for proper credentialing is required to establish that an employee or FDR or employee of an FDR is deemed. In the case of chains, such as chain pharmacies, each individual location must be enrolled into Medicare Part A or B to be deemed. See examples of such entities in Pub. 100-16, Medicare Managed Care Manual, Chapter 6 §70.

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OIG & GSA Exclusions Screening

All employees, officers and directors, governing body members, subcontracts, consultants, and vendors as applicable, must be screened against both the OIG and GSA exclusions lists prior to hire or contracting and monthly thereafter. You must notify iCare immediately in the event an excluded individual or entity is identified. Excluded persons or entities are prohibited from receiving payment.

Records of exclusion screening should clearly identify the search name, date, database, and results.

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Delegated Functions Related to iCare's Medicare Contract

If any functions related to services you provide applying to iCare’s Medicare contract are subcontracted to a downstream entity, you are obligated to ensure all CMS requirements are met. iCare also retains the right to conduct oversight activities.

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Retain Compliance Program Materials & Documentation

Sponsors are accountable for maintaining compliance program records for a period of 10 years including time, attendance, topic, certificates of completion (if applicable), and test scores of any tests administered to their employees or contracted entities.

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Additional Resources Return to Top
Report Concerns

You can report concerns by:



Calling: 1-877-5-THE-KEY (1-877-584-3539)

Phone: English 1-800-614-4126

Fax: 1-920-339-3613

Mailing: Humana, Special Investigation Unit, 1100 Employers Blvd., Green Bay, WI 54344

*Anonymous Reporting Option

iCare enforces a strict no-tolerance policy for intimidation, retaliation, or retribution against any reporter who in good faith reports suspected Fraud, Waste, or Abuse or suspected compliance concerns. Reporters are protected from retaliation for False Claims Act complaints, as well as any other applicable anti-retaliation protections.

In the event of a report, iCare will provide the reporter, if not reported anonymously, information regarding expectations of a timely response, confidentiality, non-retaliation and progress reports.

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Last Updated 4/8/21


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