The Accountable Care Organization, Ltd. (TACO) Compliance

The ACO Compliance Office oversees TACO’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 ACOs. If you have any questions or concerns regarding ACO Compliance please contact Stephanie Clark at acocompliance@priviahealth.com or stephanie.clark@priviahealth.com.

TACO 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

TACO’s 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 TACO’s ACO 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 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:

Compliance and Operational Policies

Please take some time to review TACO’s compliance and operational policies; these policies outline the laws, regulations and internal requirements we must adhere to. Please contact the ACO Compliance Officer with any questions.

Compliance Policies

Operational Policies

Written Operational Plan

To comply with the Medicare Shared Savings Program (MSSP) regulation 42 CFR 425.112(b)(4)(ii), Privia’s ACOs must detail their strategy for executing the following actions in a written operational plan:

  • Implement Individualized Care Programs: Develop and put into practice individualized care programs to improve outcomes, focusing on high-risk patients and those managing multiple chronic conditions.
  • Expand Target Populations: Identify additional populations that would benefit from individualized care plans, ensuring plans incorporate available community resources.
  • Maximize Enabling Technologies: Actively encourage and promote the use of advanced technologies to enhance care coordination for beneficiaries. This includes leveraging:
    • Electronic health records (EHRs) and other health IT tools.
    • Telehealth services, including remote patient monitoring.
    • Secure electronic exchange of health information.
    • Electronic tools designed to engage beneficiaries in their own care.
  • Establish Strategic Partnerships: Form collaborations with long-term and post-acute care providers, both within and outside the ACO, to improve care coordination for assigned beneficiaries.

Beneficiary Notifications

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

OIG/GSA Exclusion Screening

ACO Participants must not knowingly hire, employ or contract with an individual or entity that has been excluded from participation in any federal health care program. All ACO Participants must screen their workforce prior to hire and monthly thereafter.

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.

ACO Participation Agreement 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 TACO’s participation agreement.