Published February 2024

MVP provides this Code of Ethics and Business Conduct Summary as part of its commitment to conducting business with integrity and in accordance with applicable  federal, state, and local laws. This summary provides MVP’s network Providers, vendors, and delegated entities (“Contractors”) with a formal statement of MVP’s commitment to the standards and rules of ethical business conduct. All MVP Contractors are expected to comply with the standards as highlighted below. Contractors may access MVP’s full Code of Ethics and Business Conduct here.

Protecting Confidential and Proprietary Information

It is of paramount importance that MVP’s Member and proprietary information be always protected. Access to proprietary and Member information should only be granted on a need-to-know basis and great care should be taken to prevent unauthorized uses and disclosures. MVP’s Contractors are contractually obligated to protect Member and proprietary information.

Complying with the Anti-Kickback Statute

As a Government Programs Contractor, MVP is subject to the federal anti-kickback laws. The anti-kickback laws prohibit MVP, its employees, and Contractors from offering or paying remuneration in exchange for the referral of Government Programs business.

Reviewing the Federal and State Exclusion, Preclusion, and Identification Databases

MVP and its Government Programs Contractors are required to review the applicable federal and/or state exclusion, preclusion, and identification databases. These database reviews must be conducted to determine whether potential and current employees, Contractors, and vendors are excluded or precluded from participation in federal and state sponsored health care programs. The federal and state databases are maintained by the Centers for Medicare and Medicaid Services (“CMS”), the Department of Health and Human Services (“HHS”),the Office of Inspector General (“OIG”), the General Services Administration (“GSA”), the New York State Office of Medicaid Inspector General (“OMIG”), the Social Security Administration Death Master File (“SSADMF”), and the National Plan and Provider Enumeration System (“NPPES”). 

Prohibiting the Acceptance of Gifts

MVP prohibits employees from accepting or soliciting gifts of any kind from MVP’s current or prospective vendors, suppliers, Providers, or customers that are designed to influence business decisions.

Detecting and Preventing Fraud, Waste, and Abuse (FWA)

MVP has policies and processes in place to detect and prevent fraud, waste, and abuse (“FWA”). These policies outline MVP’s compliance with the False Claims Act and other applicable FWA laws and regulations. These laws and regulations prohibit MVP and its Contractors from knowingly presenting or causing to present a false claim or record to the federal government, the State Medicaid program, or an agent of these entities for payment or approval. Contractors may access MVP’s policy for Detecting and Preventing FWA here. MVP’s Special Investigations Unit (“SIU”) is instrumental in managing the program to detect, correct, and prevent FWA committed by Providers, Members, subcontractors, vendors, and employees. The SIU maintains a toll-free, 24-hour hotline, 1-877-835-5687, where suspected fraud, waste, and abuse issues can be reported directly by internal and external sources.

Providing Compliance Training FWA Training, and HIPAA Training

To prevent and detect FWA, all MVP’s Contractors that support its Medicare products and who are first tier, downstream, or related entities (“FDRs”) are required to provide general compliance training and FWA training to their employees, subcontractors, and downstream entities upon hire, annually, and as changes are implemented. The Centers for Medicare & Medicaid Services(“CMS”) provides a Medicare Parts C and D FWA and general compliance training program. This online program is available through the CMS Medicare Learning Network. Entities who have met the FWA certification requirements through enrollment into Parts A or B of the Medicare Program or through accreditation as a supplier of DMEPOS are deemed to have met the FWA training requirement. However, these entities must provide general compliance training.

MVP’s Contractors that support its Medicaid products are also required to provide general compliance and FWA training to their employees, subcontractors, and downstream entities upon hire, annually, and as changes are implemented.

In addition, Contractors who handle MVP Protected Health Information are required to provide HIPAA Privacy, Security, and Breach Prevention trainings to their employees.

Reporting Suspected Violations

MVP provides an Ethics & Integrity Hotline for reporting suspected violations of the Code or of its legal requirements. The Ethics & Integrity Hotline - 1-888-357-2687 - is available for employees, vendors, and Contractors to report suspected violations anonymously. Reports of suspected fraud, waste, and abuse may also be reported anonymously by contacting the Ethics and Integrity Hotline. EthicsPoint manages MVP’s confidential reporting system and receives calls made to the Hotline. EthicsPoint triages reports in a secure manner to MVP’s Compliance Office. The Compliance Office promptly and thoroughly investigates all allegations of violations. All MVP Contractors are required to report actual or suspected non-compliance and FWA that impacts MVP using the hotlines referenced above. Contractors are protected from intimidation and retaliation for good faith participation in MVP’s Compliance Program.

Important Updates

Review other articles in this issue regarding important updates.