GlobalHealth has a written code of conduct that every GlobalHealth employee, agent and first-tier, downstream and related entity (FDR) is required to follow.

All employees, officers, directors, business associates and FDRs are expected to report known or suspected compliance violations. Members are encouraged to report any suspected compliance violation or concern and/or fraud, waste or abuse. GlobalHealth maintains a toll-free anonymous reporting hotline available to anyone to call and report a compliance violation or concern.

Reports may be submitted openly or anonymously. Should you have a concern about a possible compliance violation or potential fraud, waste or abuse, you may contact us through the following Confidential Reporting Lines: ACTright Hotline (available 24 hours/7 days) at 1-877-627-0004 or Web Reporting Line at globalhealth.ethicspoint.com

Fraud is knowingly and willfully executing, or attempting to execute, a scheme or artifice to defraud any health care benefit program or to obtain (by means of false or fraudulent pretenses, representations, or promises) any of the money or property owned by, or under the custody or control of, any health care benefit program.

Waste is the over-utilization of services, or other practices that, directly or indirectly, result in unnecessary costs to the Medicare Program. Waste is generally not considered to be caused by criminally negligent actions but rather the misuse of resources.

Abuse includes actions that may, directly or indirectly, result in unnecessary costs, improper payment, payment for services that fail to meet professionally recognized standards of care, or services that are not medically necessary.

A First Tier Entity is any party that enters into a written arrangement, acceptable to CMS, with an MA organization 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 CFR §§ 422.500 and 423.501.)

A Downstream Entity 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 MA organization 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 CFR §§ 422.500 and 423.501.)

A Related Entity means any entity that is related to an MA organization or Part D sponsor by common ownership or control and:

1. Performs some of the MA organization or Part D plan sponsor’s management functions under contract or delegation
2. Furnishes services to Medicare enrollees under an oral or written agreement
3. Leases real property or sells materials to the MA organization or Part D plan sponsor at a cost of more than $2,500 during a contract period (See 42 CFR §§ 422.500 and 423.501.)