The Corporate Compliance Program is composed of eight (8) elements. The following represents a brief description of each element:

1. Written Policies, Procedures and Standards of Conduct.

   SOLIS has established a standardized method for the development, management and administration of policies and procedures and has a Code of Ethics and Standards of Conduct that demonstrates the organizations ethical attitude and emphasizes our commitment to compliance with all applicable Laws. SOLIS policies and procedures and Code of Ethics and Standards of Conduct are issued to all employees upon hire and upon request. Additional clarifications regarding compliance guidance are issued in various publications of SOLIS.

2. Compliance Officer, Compliance Committee and High-level Oversight.

   SOLIS has a Compliance Officer, who serves as the Chair of the Compliance, Audit and Risk Committee. The Committee meets regularly throughout the year and additional information regarding these meetings or the Compliance Officer responsibilities are available upon request.

3. Effective Training and Education.

   A comprehensive and structured compliance and fraud, waste and abuse training program are provided to SOLIS employees as part of new-hire onboarding and annual training. Training is also required for temporary staff consultants and our FDRs. Employees are required to complete this training within the first 30 days of new hire and annually thereafter. This training includes specific examples of what constitutes fraud, waste, abuse, and overpayment. Training verification is obtained through a signed and dated acknowledgement by the employee. All employees are required, as a condition of employment, to complete the annual training and acknowledge their ongoing duty to report suspected or confirmed violations of the Compliance Program or fraud and abuse issues to the Compliance Officer and other appropriate authorities.

4. Effective Lines of Communication.

   SOLIS is committed to establishing and maintaining an environment which fosters effective communication throughout all levels of the organization. The Compliance Officer encourages effective communication by being available to all board members, officers, directors, managers, employees, first tier, downstream and related entities for the reporting of potential instances of fraud, abuse or other compliance related concerns. Compliance utilizes a variety of methods to encourage communication including, but not limited to, email, face-to-face and published hotline numbers.

5. Well Publicized Disciplinary Standards.

   Employees are expected to abide by the standards and policies adopted by the organization and will enforce non-compliance with these standards and policies in a timely, fair, equitable, and consistent manner. Standards are described in the Code of Ethics and Standards of Conduct which includes expectations for reporting compliance violations and how to identify non-compliant or unethical behavior.

6. Effective System for Routine Monitoring and Identification of Compliance Risks.

   To confirm compliance with Medicare regulations, sub-regulatory guidance, contractual agreements, and all applicable Federal and State laws, as well as internal policies and procedures to protect against Medicare Parts C & D program noncompliance and potential FWA, SOLIS has established routine monitoring and auditing activities. SOLIS may enter into contracts with FDRs to provide administrative or health care services for enrollees on behalf of the plan. However, SOLIS maintains the ultimate responsibility for fulfilling the terms and conditions of its contract with CMS, and for meeting the Medicare program requirements.

7. Procedures and System for Prompt Response to Compliance Issues.

   SOLIS has established documented procedures and a system for promptly responding to compliance issues as they are raised, investigating potential compliance problems as identified in the course of self-evaluations and audits, correcting such problems promptly and thoroughly to reduce the potential for recurrence, and ensuring ongoing compliance with CMS requirements.

8. Identification of Compliance Risk - Risk Assessment.

   SOLIS recognizes risk assessments are very important and form an integral part of plan management. As part of its commitment to risk aversion and remediation, SOLIS, after 1 year of operation, will perform a baseline assessment of major compliance and FWA risk areas through a risk assessment. Each operational area will be assessed for the types and levels of risks the area presents to the Medicare program and SOLIS.

If you have a concern related to compliance or ethics we encourage you to report it. Any person, including SOLIS members, provider or FDRs, may confidentially or anonymously report suspected or known issues of non-compliance or ethic violations by calling the Compliance Hotline toll-free at 833-720-0006 (USA and Canada only) available 24 hours a day and 7 days a week provided by LightHouse Services. Email your incident to reports@lighthouse-services.com , fax your compliance incident to 215-689-3885 (must include the company name on the email and fax) or submit an incident report through the lighthouse website: www.lighthouse-services.com/solishealthplans. In addition, if you would like to receive a copy of the SOLIS Corporate Compliance Program Description you may send a written request to:

SOLIS Health Plans, Inc. (HMO)

Attention: Corporate Compliance Office

9250 NW 36TH Street, Suite 400

Doral, FL 33178

Please be sure your request includes your full name and the complete mailing address of where we should send the request material.

Health care fraud, waste and abuse affects all of us. It impacts the quality of health care and results in higher medical and prescription costs. There are many different types of fraud, waste and abuse. It’s important to be able to identify these issues and know what to look for to protect yourself from identify theft and benefit fraud.

Be suspicious of:

• People trying to sell you health care items or services door-to-door or over the phone.

• People who offer money or gifts for health care services.

• People offering you free gifts or services in exchange for your Medicare ID number or health plan ID number.

• Shipments of medical supplies you didn’t order.

• Providers who tell you the item or service isn’t usually covered, but they “know how to bill” so insurance will pay.

Below are some other things you should be aware of to protect yourself from fraud, waste and abuse.

Online theft of personal information

• People may try to steal your personal or Medicare information online. They can harm you financially. They may also disrupt your healthcare benefits.

• It’s not always easy to tell the difference between an important email about your benefits and an online scam. An email may say there’s a problem with your account. Or it may ask for updated information to continue your healthcare coverage. When in doubt, give us a call at the Member Services number on your Id card. Where here to help.

Telemarketing scams

Many legitimate businesses use telemarketing. But criminals can also use live or recorded calls to try to steal your identify. Medicare won’t call to ask for your bank account number, Social Security Number, Medicare ID number or health plan ID number and neither will SOLIS.

To protect yourself:

• Hang up on recorded messages that ask you to verify your personal information.

• Don’t press any keys or numbers when prompted – even if it’s to take your name off their list.

• Never give your personal information to someone you don’t know.

• Report suspicious numbers to the Federal Trade Commission.

Things you can do to protect yourself and your benefits against fraud:

• Never give out your Social Security, Medicare ID number, health plan ID number or banking information to anyone you don’t know. You should only provide this information to people you know should have it.

• Know who you’re sharing your personal information with.

• When you receive a bill for services review it carefully.

  • Make sure you received the services or items.

  • Check the number of services or items on your bill or explanation of benefits.

  • Be sure the same service isn’t on your bill more than once.

  • Verify the copayment amount is correct.

• If you think a charge is incorrect and you know the provider, you may want to call their office to ask about it. The person you speak to may help you better understand the services or supplies you got. Ask about the services you receive, such as: Why are they needed?

• Or, your provider may realize a billing error was made.

• Delete or ignore suspicious emails. Don’t click or download attachments you aren’t expecting. Legitimate email addresses usually end in .com, .org or .gov.

• If you are unsure about information you have received about your benefits, please call our Member Services department at the number on your SOLIS ID card.

Report concerns to us:

• If you see something suspicious or have a question about your plan statement or benefits, call our Member Services department at the number on your ID card. You may also report your concerns anonymously by calling the Compliance Hotline toll-free at 833-720-0006 (USA and Canada only) available 24 hours a day and 7 days a week provided by LightHouse Services.

• You can also report suspected fraud or abuse directly to Medicare. Call the Medicare fraud tip line at 1-800-HHS-TIPS (1-800-447-8477). The TTY number is 1-800-377-4950. Email: You can also send up to 10 pages describing the incident to HHSTips@oig.hhs.gov.