ACO Compliance
The Compliance Office oversees Privia’s ACO Compliance Program and is led by Stephanie Clark, Director, Compliance and ACO Compliance Officer. The ACO Compliance Officer is responsible for the day-to-day direction and implementation of the compliance program and works closely with ACO Leadership to ensure compliance in all ACO’s. If you have any questions or concerns regarding ACO Compliance please contact Stephanie Clark at stephanie.clark@priviahealth.com.
ACO Compliance Resources
Code of Conduct
Privia’s Code of Conduct reflects our values and applies to every one of us, regardless of our job titles. The Code of Conduct is a valuable resource that provides important information about compliance-related topics. Please join us in doing your part by reading our Code of Conduct and understanding how you can embrace its concepts. All of us have a personal responsibility to ensure we conduct our business in a manner that reflects the highest standards of honesty and integrity.
ACO Compliance Plan
The ACO Compliance Plan describes how Compliance Program elements are met for the ACO in accordance with the Medicare Shared Savings Program (MSSP) regulation. It also establishes how the Compliance Plan promotes regulatory compliance and prevents, detects and resolves non-compliant and illegal conduct, including fraud, waste and abuse (FWA) of government program funds by those participating in or otherwise providing services to the ACO. Please take some time to read the ACO Compliance Plan to familiarize yourself with the ACO’s Compliance Program and your role in ensuring compliance.
Reporting Mechanisms
Privia and the ACO are committed to providing an environment free from retaliation or intimidation. There will be no retaliation or intimidation against anyone for good faith participation in the Compliance Program, including the reporting of compliance concerns or suspected or actual violations of laws, rules, compliance program policies or any other inappropriate behavior. The ACO provides multiple reporting mechanisms, including the ability to report concerns anonymously. Compliance concerns may be reported to:
- The ACO Compliance Officer: stephanie.clark@priviahealth.com;
- Privia’s Chief Audit and Compliance Officer: dana.fields@priviahealth.com;
- Compliance Office: compliance@priviahealth.com;
- Each Privia’s employee’s immediate supervisor;
- Any member of Privia’s Executive Team;
- Privia’s Legal Department legal@priviahealth.com;
- ACO’s confidential and anonymous Compliance and Ethics Line: 877-851-8048, or
- Privia’s ComplianceLine Platform: priviahealth.com/ethicsline
ACO Compliance Policies
Please take some time to review the ACO’s Compliance Program policies; these policies outline the laws, regulations and internal requirements we must adhere to. Please contact the ACO Compliance Officer with any questions.
- ACO Beneficiary Discharge, Avoidance and Referrals
- ACO Beneficiary Incentives
- ACO Benefit Enhancements
- ACO Communications and Material Review
- ACO Compliance Communications
- ACO Compliance Log
- ACO Compliance with HIPAA and DUA Requirements
- ACO Corrective and/or Disciplinary Action and Programmatic Corrections
- ACO FWA Laws and Utilization of Waivers
- ACO Governance and Public Reporting Requirements
- ACO Repayment Mechanisms
- Compliance Training
- Compliance Training – North Texas
- Conflicts of Interest
- Exclusion Monitoring
- Fraud Waste and Abuse Laws
- Non-Discrimination and Limited English Proficiency
- Non-Retaliation Policy
- Retention of Documents
- Whistleblower Policy
Privia Quality Network Written Operational Plans
The PQN Operational Plans outlined in this document promote individualized care programs for improved outcomes for high-risk and multiple chronic condition patients. Depending on the operational state of the ACO, the plans outlined in this document may, or may not be, incorporated into day-to-day operations. This operational plan meets the requirements in 42 CFR 425.112(b)(4)(ii).
ACO Participation Agreements with CMS
The ACO must provide a copy of its participation agreement with CMS to all ACO participants, ACO providers/suppliers, and other individuals and entities involved in ACO governance. Below you will find participation agreements applicable to each Privia ACO.