Compliance & Ethics

Our Commitment to Doing Things Right

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.

Core Elements of Our Compliance Program

Our program is built on established healthcare compliance standards and tailored to the specific requirements of the CMS LEAD Model.

Written Code of Conduct

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.

Required Compliance Training

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.

Confidential Reporting Mechanism

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.

Routine Auditing and Monitoring

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.

CMS Cooperation and Reporting

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.

Enforcement and Discipline

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

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:

Patient-centered care and the protection of beneficiary rights
Accurate and honest reporting of quality measures and financial data
Compliance with anti-kickback, Stark Law, and self-referral prohibitions
Protection of patient health information under HIPAA
Transparency in our relationships with providers and partners
Proper use of Medicare funds and ACO shared savings
Conflicts of interest identification and management

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.

Healthcare compliance documentation and review

How to Report a Concern

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.

Reporting Channels

You can report a concern through any of the following channels. All reports are taken seriously and investigated promptly.

Compliance Email compliance@citycarepartners.com
Compliance Hotline (Confidential) +1 347-534-2516
Mail Compliance Officer, City Care Partners
575 8th Ave Floor 10,
New York, NY 10018, United States

What to Report

Reports can cover a wide range of concerns. Examples include, but are not limited to:

Fraud, Waste, or Abuse Suspected false claims, billing irregularities, or misuse of Medicare funds
Privacy or Security Breaches Unauthorized access to or disclosure of patient health information
Kickbacks or Improper Incentives Payments or inducements intended to influence referrals or clinical decisions
Quality Reporting Concerns Inaccurate or manipulated quality measure data submitted to CMS
Conflicts of Interest Undisclosed financial relationships that may affect clinical or business decisions

Non-Retaliation Policy

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.

Regulatory Framework

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:

Federal Anti-Kickback Statute (AKS) — Prohibits offering, paying, soliciting, or receiving anything of value to induce or reward referrals for services covered by federal healthcare programs.
Physician Self-Referral Law (Stark Law) — Prohibits physicians from referring Medicare or Medicaid patients for designated health services to entities in which the physician or an immediate family member has a financial relationship, unless an exception applies.
False Claims Act (FCA) — Imposes liability on any person who knowingly submits, or causes to be submitted, a false or fraudulent claim for payment to the federal government.
Health Insurance Portability and Accountability Act (HIPAA) — Establishes national standards for the protection of individually identifiable health information, including the Privacy Rule, Security Rule, and Breach Notification Rule.
CMS LEAD Model Participation Agreement — The terms and conditions set forth by CMS for all organizations participating in the LEAD Model, including requirements related to governance, beneficiary notification, data sharing, quality reporting, and financial arrangements.
42 CFR Part 425 (Medicare Shared Savings Program Regulations) — Federal regulations governing ACO participation, including requirements for compliance programs, beneficiary engagement, and financial reporting.