First Tier, Downstream and Related Entities
Memorial Hermann Health Solutions, Inc. (MHHSI) is contracted with the Centers for Medicare and Medicaid Services (CMS) and is required to adhere to all federal and state regulations. Any First Tier, Downstream & Related (FDR) entities contracted to provide services for MHHSI will be required to adhere to the same contractual obligations as MHHSI. As an FDR of MHHSI you are required to validate and show proof of the following criteria annually; items such as:
- Annual Compliance Attestation
- Validation of Completion of Fraud, Waste and Abuse (FWA), Compliance, and HIPAA Training
- Monitoring of the Office of Inspector General (OIG) List of Excluded Individuals and Entities (LEIE) database
- Subcontractor and vendor oversight
In order to ensure that all FDR's contracted to provide services for MHHSI meet the CMS requirements, the Delegation Oversight unit of MHHSI will conduct annual oversight to ensure that the FDR’s continue to meet the CMS and contractual obligations on an ongoing basis.
If you have any questions regarding the Delegation Oversight process you can contact us at: MHHealthComplianceOversight@memorialhermann.org.
First Tier: Any party that enters into a written arrangement acceptable to CMS with MHHSI to provide administrative services or health care or pharmacy services for a Medicare eligible individual under a MA or Part D Plan.
Downstream: Any party that enters into a written arrangement, acceptable to CMS, below the level of the arrangement between MHHSI and a first tier entity. These written arrangements continue down to the level of ultimate provider of health, pharmacy and/or administrative services to members.
Reporting to Compliance
Memorial Hermann Health Solutions, Inc. has adopted processes to receive, record and respond to compliance questions, reports of potential or actual non-compliance, and Fraud, Waste and Abuse (FWA) from employees, contractors, vendors, providers and members. Memorial Hermann Health Solutions, Inc. maintains confidentiality to the extent possible, allows anonymity if desired, and ensures non-retaliation against those who report suspected misconduct in good faith.
Memorial Hermann Corporate Compliance and Ethics Hotline:
- 713-338-4140 or 1-877-448-4140
- Para ayuda en Español: 800-297-8592
You may contact us in writing at:
Memorial Hermann Health Solutions, Inc.
929 Gessner Rd. Suite 1500
Houston, TX 77024
Or you may submit reports of potential or actual non-compliance to us through this online form.