Compliance
West Virginia Senior Advantage Compliance Program
WEST VIRGINIA SENIOR ADVANTAGE, INC.
The West Virginia Senior Advantage (WVSA) Compliance Program (Compliance Program) applies to Medicare Part C and Part D. The Compliance Program is reviewed and updated annually and as applicable,
and is approved by the Board of Directors.
The Compliance Program is a component of the overall CommuniCare
Health Services (“CHS” or “Company”) Compliance Program and reinforces
the Company’s commitment to comply with all applicable Federal and State
standards as well as ethical standards of conduct. The overall Compliance
Program and the Company Code of Conduct and Ethics is endorsed and
approved by the Company’s Board of Directors.
The Compliance Audit Plan is approved by the Audit Committee a subcommittee of the Board of Directors.
WEST VIRGINIA SENIOR ADVANTAGE BUILDS ON THE FOUNDATION ESTABLISHED BY THE COMPANY’S CORPORATE COMPLIANCE PROGRAM, INCLUDING:
• Measures related to mandatory compliance training
• HIPAA privacy program training, and fraud, waste and abuse (“FWA”) detection
• Prevention and correction, including a hotline for anonymous reporting
• Specialized training for functional areas supported by department policies and procedures
A key element in the Compliance Program is the creation of a Compliance
Committee, which is charged with supporting the Compliance Officer in review and oversight of the WVSA’s Compliance Program.
The Committee reports to WVSA’s senior management, the Chief Executive Officer (CEO), and Board of Directors which reviews the effectiveness of the
Compliance Program through self-audits and monitoring of metrics and key indicators, and to ensure prompt and effective corrective actions are taken
where deficiencies are noted.
The Compliance Officer and the Committee are responsible for escalating
compliance deficiencies and ongoing issues of noncompliance to Senior
Management, the CEO, and the Board of Directors. WVSA makes the
Compliance Plan available to all Plan employees and the Board of Directors,
as well as contractors, subcontractors, vendors, agents, and first-tier,
downstream and related entities (“FDRs”).
The Compliance Officer reserves the right to amend and update components
of the Compliance Plan at any time to make changes based on regulatory
guidance, enhancements to the program to improve effectiveness.
For the purpose of this website, the term “WVSA programs” includes all the
Medicare Advantage (“MA”) Part C and Part D Prescription Drug (“Part D”)
lines of business, and the term “employees” includes permanent employees,
temporary employees, and volunteers of the health plan. All employees,
non-employees and Board of Directors’ members who support WVSA
programs must read and understand the content of the Compliance Plan
and associated policies and procedures. Written Policies, Procedures, and
Standards of Conduct are an integral part of the Plan for information
regarding applicability to FDRs. WVSA also maintains disaster and emergency policies for compliance with guidance on minimizing disruptions in access to health care.
Please contact the Health Plan Compliance department if you have questions regarding the Compliance plan or to report compliance issues or fraud, waste or abuse. You can also call the Ethics & Compliance Action Line at (800) 238-1770 or by email at Healthplan-compliance@chs-corp.com.