Medicare Advantage Compliance Attestation
Delta Dental of Colorado’s compliance program is our commitment to business integrity and ethical behavior. Part of this commitment is ensuring we are in full compliance with our obligations and responsibilities as a First-Tier entity to the Medicare Advantage Organizations (MAO) with which we contract. Your written agreement with Delta Dental of Colorado, as the ultimate provider of health or administrative services for Medicare Advantage dental benefits, means your organization is considered a downstream entity. Delta Dental of Colorado is required to monitor and ensure your organization operates in compliance with applicable laws and regulations required by the Centers for Medicare and Medicaid Services (CMS) and your contract with Delta Dental of Colorado.
As part of DDCO’s commitment to adhering to all Centers for Medicare & Medicaid Services (CMS) regulations, it is essential that any downstream entity, including your dental office, complies with the same rules and regulations.
In 2024, CMS provided clarification regarding regulation 42 CFR § 422.105. We want to ensure you are fully informed of this provision and its requirements. According to 42 CFR § 422.105 and the Medicare Managed Care Manual (MMCM), members/patients must be notified in advance if a covered service will be denied based on the plan benefits provision. If notice is not provided (typically via a predetermination of benefits or patient consent form), the member/patient cannot be held liable for the amount the carrier would have paid. This amount becomes a write-off/adjustment for the contracted Delta Dental Medicare Advantage provider. However, the patient remains liable for the amount calculated per the cost-sharing provisions.
For more information regarding this regulation and others, please visit CMS at CMC.gov and search for 42 CFR § 422.105.
By signing this attestation, you are affirming your commitment to comply with each of the following program requirements that apply to your organization and the services you provide for Medicare Advantage business. You are signing this attestation as part of the required attestation process, and your participation in the Delta Dental Medicare Advantage network is active for all locations where you provide treatment for Medicare Advantage members.
Fraud, Waste, and Abuse (FWA) and General Compliance Training
My organization provides all employees and subcontractors fraud, waste, and abuse and general compliance training* within 90 days of hiring and annually thereafter. The following training modules are incorporated into our training and/or written documents:
Report FWA and Non-Compliance or HIPAA Issues
My organization understands that it must report any suspected or known FWA or non-compliance or HIPAA concerns to Delta Dental of Colorado's hotline at 1-833-430-0255, compliance@ddpco.com, or go to deltadentalco.com/members/fraud-abuse-form.html on Delta Dental of Colorado’s website to complete and submit the Fraud, Waste, and Abuse form, so that reports can be made to all impacted MAOs. My organization has communicated to employees and subcontractors on how to report the suspected or known FWA or non-compliance concerns and that they are obligated to do so without fear of retaliation or intimidation.
Office of Inspector General (OIG) and General Services Administration (GSA) Exclusion Screening
My organization and I review the Office of Inspector General (OIG) List of Excluded Individuals and Entities (LEIE) and General Services Administration (GSA) List for our employees, temporary employees, board members, volunteers, and contractors involved in the administration and delivery of services to Medicare Advantage enrollees. Exclusion screenings from these sources are checked prior to initial hire or contracting and monthly thereafter. Any individual found on such lists will immediately be removed from any work directly or indirectly related to Medicare Advantage programs.
Record Retention
My organization and I agree to maintain records of compliance training, disciplinary standards, investigations, compliance program materials, and exclusion checking for all employees, including temporary employees and volunteers, board members, and downstream entities, for a minimum of 10 years. Records maintained must include but are not limited to training materials and training logs, documentation of exclusion checks, and dissemination of compliance program policies.
Offshore Subcontractor Reporting
My organization does not perform any work nor has any subcontractors that perform any work offshore that involves the receipt, processing, transferring, handling, storing, or accessing of protected health information (PHI) belonging to any Medicare Advantage beneficiaries.
If my organization uses an Offshore Subcontractor, a signed Offshore Contractor Attestation Form linked below will be completed.
Attestation Authorization
I certify that by checking the box below, the information above is true and correct to the best of my knowledge and the above compliance program requirements have been met. In addition, my organization and I will furnish evidence of completion of the above to Delta Dental of Colorado upon request for monitoring and auditing purposes.
*The training module made available by DDCO is an option of what can be used as your training module to meet the requirement; however, it’s not the only option and does not have to be what you use to meet the requirement.
Every provider practicing within the Medicare Advantage Network is REQUIRED to complete this attestation annually. This year it is due by April 13, 2026.
Completion of all fields below is required