Welcome to the Compliance Department Site

Leon Health Plans, Inc. Compliance Hotline

Leon Health prides itself on a culture of openness, trust, and integrity. Effective ethics is a team effort involving the participation and support of every employee. We will not tolerate any wrongdoing or impropriety at any time and management will take the appropriate measures and act quickly in addressing any issues or infractions of this policy. We will promote a trustworthy and honest work atmosphere and we will reinforce the vision of these ethics within the organization.

How to report compliance concerns

To support this culture, Leon Health has contracted with Lighthouse to provide you with an easy and anonymous way to report code of conduct violations and non-compliance issues. Below are ways you may report violations or non-compliance issues:

What are First-Tier, Downstream and Related Entities (FDRs)?

  • First Tier Entity (FTE) is any party that enters into a written arrangement, acceptable to CMS, with a Medicare Advantage Organization (MAO) or Part D plan sponsor or applicant to provide administrative services or health care services to a Medicare eligible individual under the MA program or Part D program. (See, 42 C.F.R. § 423.501).
  • Downstream Entity (DSE) is any party that enters into a written arrangement, acceptable to CMS, with persons or entities involved with the MA benefit or Part D benefit, below the level of the arrangement between an MAO or applicant or a Part D plan sponsor or applicant and a first-tier entity. These written arrangements continue down to the level of the ultimate provider of both health and administrative services. (See, 42 C.F.R. §, 423.501).
  • Related Entity (RE) means any entity that is related to an MAO or Part D sponsor by common ownership or control and
  • (1) Performs some of the MAO or Part D plan sponsor’s management functions under contract or delegation;
  • (2) Furnishes services to Medicare enrollees under an oral or written agreement; or
  • (3) Leases real property or sells materials to the MAO or Part D plan sponsor at a cost of more than $2,500 during a contract period. (See, 42 C.F.R. §423.501).

Leon Health’s Policies & Procedures

Leon Health (LH) FDRs may have their own Policies and Procedures (P&Ps). However, they must incorporate the seven elements of an effective compliance program as outlined by CMS. FDRs may use Leon Health’s internal compliance P&Ps as a resource to develop their own.

FDR compliance guidelines are instrumental in upholding legal standards, ensuring program integrity, protecting Leon Health’s members, maintaining data security, promoting consistency in service delivery, and mitigating risks. By following these guidelines, FDRs contribute to the overall success and effectiveness of Leon Health, Inc.

Leon Health’s Code of Conduct

Leon Health (LH) FDRs may have their own Code of Conduct. However, it should describe the FDR’s expectations that all employees conduct themselves in an ethical manner; that issues of noncompliance and potential FWA are reported through appropriate mechanisms; and that reported issues will be addressed and corrected. FDRs may use Leon Health’s code of conduct as a resource to develop their own. Otherwise, FDRs may adopt Leon Health’s code of conduct to meet the necessary requirements.

Effective Training and Education for FDRs

We require our FDR entities to distribute its Compliance Policies & Procedures and Code of Conduct and retain evidence of distribution. In addition, FDRs must administer General Compliance and FWA training to all its employees. These requirements must take place upon hire or contract initiation, and then annually thereafter.

Attestation for FDRs

All FDRs are required to annually endorse the FDR Attestation. This crucial step aids us in showcasing to CMS our effective communication of CMS’ requirements and verifying the compliance of our FDRs with these standards.

FDRs Exclusion List Screenings

Leon Health will be conducting exclusion screenings of our FDRs prior to contracting, and monthly thereafter. However, each FDR is required to conduct exclusion screenings of their employees and subcontractors against the Office of Inspector General (OIG) and
GSA Excluded Parties Lists System (EPLS). This will help in verifying that your employees and downstream entities are not barred from participating in federally funded healthcare programs.

Your partnership is more than just a professional collaboration; it is a shared commitment to enhancing the health and well-being of Leon Health’s members.

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