CMG ACO, LLC (CMG) 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.

CMG 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.

CMG Compliance Plan

CMG’s ACO Compliance Plan describes how Compliance Program elements are met for CMG 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 Compliance Plan to familiarize yourself with the ACO’s Compliance Program and your role in ensuring compliance.

Reporting Mechanisms

Privia’s Ethics Line is a method for employees or contractors of the ACO, ACO participants, ACO providers/suppliers, and other individuals or entities performing functions or services related to ACO activities to anonymously report suspected problems related to the ACO to the compliance officer.

Privia and CMG 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. CMG provides multiple reporting mechanisms, including the ability to report concerns anonymously. Compliance concerns may be reported to:

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.

Beneficiary Notifications

Beneficiary notifications must be posted in all Participant facilities and provided to Medicare beneficiaries as required in 42 CFR 425.312. Also, care centers must maintain records according to CMS requirements, as stated in 42 CFR 425.314.

CMG’s Participation Agreement with CMS

CMG 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 the participation agreement applicable to CMG.

ACO Compliance Training and Log

The ACO, ACO participants, and ACO providers/suppliers must receive compliance training. You must maintain training records for this ACO compliance training.

OIG Compliance Resources

As a provider serving Medicare patients, your Care Center must establish a compliance program. The OIG has published compliance resources for healthcare providers.

General Compliance Training

Providing comprehensive education and training is a vital component of an effective compliance program.We have provided copies of Privia’s Fraud, Waste and Abuse, and HIPAA Privacy and Security training as resources.

These training materials are intended to provide general examples, are not exhaustive, and do not constitute legal advice. Additional content and training may be needed to meet your organization’s specific compliance requirements.