Compliance

The Privacy Rule provides federal protections for individually identifiable health information held by covered entities and their business associates; and gives patients an array of rights with respect to that information.

Privacy Policy

This privacy policy notice describes our privacy practices and how we collect, use and disclose individually identifiable information with respect to our health insurance products subject to HIPAA. It also explains how we collect, use and disclose non-public personal financial information with respect to our insurance products subject to the Gramm-Leach-Biley Act. This Request for PHI notice is for your information and provides how you can access your information.

Standards of Conduct

Memorial Hermann Health Plan has a Standards of Conduct document that includes our written commitment to compliance and ethical behavior, including federal and state laws that apply to our business, our responsibility to report compliance issues, disciplinary actions due to noncompliance, and other compliance matters.

For Beneficiaries and Members

The team at Memorial Hermann Health Plan is dedicated to fighting health care fraud, waste and abuse, along with our network of physicians, pharmacies and other providers. Most doctors and pharmacists work ethically to provide high-quality medical care, and to submit proper claims for payment. However, there are unfortunately a few health care providers who exploit the system. Protecting your personal information is the best line of defense in the fight against health care fraud and abuse.

Things you can do to protect yourself:

  • Don't give your Medicare, Medicaid, or Social Security numbers to strangers.
  • Remember that Medicare does not call or visit to sell you anything.
  • Keep records of your doctor visits, tests, and procedures.
  • Save your Explanation of Benefits and review it for any inaccuracies.

If you are enrolled in our Medicare Advantage HMO plan and would like to learn more about Medicare fraud, please visit medicare.gov

If you suspect there has been any suspicious activity with your medical or drug claims, please call Customer Service at (855) 645-8448 (TTY 711). You may also email us at MHHealthPlanFWA@memorialhermann.org. Customer Services Representatives are available 8 a.m. to 8 p.m. CST, 7 days a week from Oct.1 – March 31 and 8 a.m. to 8 p.m. CST, Monday – Friday from April 1 – Sept. 30. 

For Employees

Memorial Hermann Health Plan 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 Plan 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:

You may also contact us by writing to:
Memorial Hermann Health Plan
Compliance-FWA Department
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

If you have questions or need guidance from the Health Plan's Compliance team, here are some ways you can reach us:

Understanding Privacy

HIPAA is the federal Health Insurance Portability and Accountability Act of 1996. It is enforced by the Office for Civil Rights. HIPAA is comprised of two rules: the Privacy Rule and the Security Rule.

The Privacy Rule provides federal protections for individually identifiable health information held by covered entities and their business associates; and gives patients an array of rights with respect to that information. At the same time, the Privacy Rule is balanced so that it permits the disclosure of health information needed for patient care and other important purposes.

The Security Rule specifies a series of administrative, physical, and technical safeguards for covered entities and their business associates to use to assure the confidentiality, integrity, and availability of electronic protected health information.

For more information, visit hhs.gov.

Contacting and Reporting to Compliance

Memorial Hermann Health Plan 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 Plan 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:

You may contact us in writing at:
Memorial Hermann Health Plan
Compliance-FWA Department
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.

If you have questions or need guidance from Health Plan's Compliance here are some ways you can reach us:

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 and 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 and items annually:

  • 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

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.

Definitions

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.

Related: Any entity that is related to MHHSI by common ownership or control and performs some of MHHSI's management functions under contract or delegation, and furnishes services to Medicare enrollees under an oral or written agreement.