Banner Health Compliance Training

Offshore Contracting Limitations If contractors, subcontractors, agents, and other persons plan to outsource any work for Banner overseas, they need to contact Banner’s Legal Department and/or the Ethics & Compliance Department. Medicare and Medicaid have specific contracting limitations for outsourcing work to other countries. Medicare Offshore Contracting Limitations ● At a minimum, CMS requires notification of any use of an offshore contractor, whether Banner contracts directly with the offshore contractor or Banner’s contractor subcontracts with an offshore entity or person ● Some of Banner’s contracts with Medicare Advantage plans further limit the use of offshore contractors ● If Banner team members are going to use an offshore contractor, they must work with Legal during the contract process to give Banner sufficient time to evaluate the limitations that may be involved.

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