City Care Partners is committed to the highest standards of integrity, transparency, and regulatory compliance in all that we do.
City Care Partners is committed to the highest standards of integrity, transparency, and compliance with all applicable federal and state laws and regulations governing Accountable Care Organizations. As a participant in the CMS LEAD Model, we take seriously the responsibility that comes with managing care coordination for Medicare beneficiaries and the stewardship of public funds.
Our Compliance Program is overseen by our Compliance Officer and reports directly to the Board of Managers. The program is designed to prevent, detect, and correct any conduct that does not comply with applicable laws, regulations, or our own ethical standards — and to create a culture where doing the right thing is expected, supported, and rewarded.
Our program is built on established healthcare compliance standards and tailored to the specific requirements of the CMS LEAD Model.
A comprehensive Code of Conduct that applies to all employees, board members, and participating providers. It establishes clear expectations for ethical behavior, clinical integrity, and regulatory compliance across every aspect of our operations.
Mandatory compliance education for all personnel, including onboarding training for new hires and annual refresher courses. Training covers fraud, waste, and abuse prevention; HIPAA privacy and security; anti-kickback statutes; and LEAD Model-specific requirements.
A confidential reporting hotline and dedicated compliance email that allow anyone — employees, providers, beneficiaries, or partners — to raise concerns about potential violations without fear of retaliation.
Regular audits and monitoring of our operations, billing practices, quality reporting, and data security to identify potential issues early and take corrective action before they become systemic problems.
Full cooperation with all CMS audits, investigations, data requests, and reporting requirements. We maintain open communication with CMS and respond promptly and transparently to all inquiries from the Innovation Center and its agents.
Consistent enforcement of our compliance standards through a defined disciplinary process. Employees and providers who violate our Code of Conduct or applicable laws are subject to appropriate corrective action, up to and including termination of employment or removal from our ACO network.
Our Code of Conduct sets the standard for how we operate. It applies to every individual who works on behalf of City Care Partners — employees, contractors, board members, and participating providers. The Code covers key areas including:
All participating providers are required to acknowledge and agree to abide by our Code of Conduct as a condition of participation in our ACO network.
If you have a concern about potential fraud, waste, abuse, or any violation of laws or City Care Partners policies, we want to hear about it. You do not need to identify yourself to make a report.
You can report a concern through any of the following channels. All reports are taken seriously and investigated promptly.
Reports can cover a wide range of concerns. Examples include, but are not limited to:
City Care Partners strictly prohibits retaliation against any individual who, in good faith, reports a concern about potential fraud, waste, abuse, or a violation of laws or company policies. This protection applies regardless of whether the report is made through the compliance hotline, by email, by mail, or directly to a supervisor. Individuals who retaliate against good-faith reporters are subject to disciplinary action, up to and including termination.
As a CMS LEAD Model participant, City Care Partners operates within a complex regulatory environment. Our Compliance Program is designed to address requirements under the following laws and regulations, among others:
Our Compliance Officer is available to answer questions, provide guidance, or receive reports. All communications are treated with confidentiality.
Contact Our Compliance Officer