Compliance with the Law

Each employee plays a crucial role in preventing, detecting, and reporting noncompliance, and possible fraud, waste, and abuse (FWA). If you suspect fraudulent activity, report it to the Special Investigations Unit (SIU) or Internal Audit Department.They will investigate the matter. If funds are missing, Premera will attempt to recover them and contact the proper authorities.

See Appendix A for links to laws that apply to fraud, waste and abuse. We all have a duty to follow these laws. Review Appendix B for the Definitions and Key Indicators of potential FWA for customers, providers, pharmacies, wholesalers, manufacturers, plan sponsors, producers, and employees.

Together we form a collective that safeguards Premera’s resources and reputation. We also reinforce our commitment to ethical conduct.

To report suspected FWA events and activities related to external parties (such as provider, pharmacy, and member), complete the Referral for Potential Fraud form and email it to Stop Fraud. You may also call the Anti-Fraud Hotline at 800-848-0244.

To report potential fraud by a Premera employee, please reach out to the Internal Audit Department. You may also call the Compliance & Ethics Hotline at 888-418-1537 if you prefer to report anonymously.

Management-level employees who are informed, or otherwise become aware, of suspected internal fraud must immediately report the suspected internal fraud to Internal Audit.

We are committed to a culture of integrity, ethical conduct, and compliance with all state and federal laws and applicable regulations. We stand firmly against any form of discrimination. We will not discriminate based on race, color, ethnicity, national origin, sex, gender identity or expression, marital status, age, sexual orientation, disability, language fluency, religion, genetic information, veteran status, or other protected categories under federal, state, or local law.

Through awareness and understanding, we create a work culture where everyone is valued, respected, and treated fairly. Each of us can contribute our unique perspective and talent. Together we foster an atmosphere of trust, collaboration, andmutual respect. This ensures that Premera is an inclusive and welcoming place for all.

Premera recognizes the importance of its partnerships with federal, state, and local governments. Doing business with the government means we have to strictly follow special laws and regulations. The consequences for violating these legal requirements can be severe.

Please note that employees of the Federal Employee Program’s Director’s Office of the Blue Cross Blue Shield Association are not considered government employees. However, it remains crucial to avoid any perception of conflicts of interest to uphold the highest standards of integrity.

It’s vital to understand how we work with the government. Refer to Appendix A for a list of the major federal laws that apply to Premera based on the federal programs in which we participate. These guidelines help us navigate our specific requirementsand obligations.

Q & A

How can I learn what laws and regulations apply to my area?

Be familiar with the corporate and departmental policies that are applicable to your job function. All corporate policies are developed and managed in conjunction with the Regulatory Compliance & Ethics department and can be found on the Corporate Policies internal website. Departmental policies and procedures are the responsibility of individual departments to create, maintain, distribute, and when necessary, to communicate important changes to employees.

Premera employees are forbidden from offering any money, gifts, services, or entertainment to government employees. Contact Regulatory Compliance & Ethics with any question about these requirements.

Q & A

I work in Claims and have been working very closely with someone from Medicare. She has been very helpful in explaining how we need to handle secondary payments. Can I send her a small gift to thank her?

No, you cannot send anything of monetary value to a government employee. Sending a nice thank you card or email would be appropriate.

We ensure our operations and supply chains are free from the practices of slavery and human trafficking, and we comply with all relevant labor standards.

Some Premera employees may not be able to work with government programs, such as Medicare Advantage. Any employee who has been debarred, excluded, or suspended from working with any governmental agency must immediately notify Regulatory Compliance & Ethics.

This is important since Medicare and other federal healthcare programs will delay payment for services performed or ordered by anyone who has been excluded from working with any government agency. We regularly review published information for excluded individuals and entities. Anyone on the list that is employed or retained by Premera is notified and given the opportunity to provide proof that they are not excluded. Exceptions may be made for sanctioned providers if they do not participate in a federal or federally funded healthcare program.

Q & A

I work in Finance and am responsible for preparing a regulatory filing every month. We recently changed systems and I’m concerned the data is incomplete. What should I do?

Discuss the situation with your management. If there are differences between what you used to report and what you are currently reporting, there could be data that wasn’t accurately converted. This needs to be resolved immediately, and any past reports with inaccurate data should be resubmitted. Contact Regulatory Affairs for additional guidance.

Former government employees may be restricted in the type of employment they can accept. These rules depend on the agency involved, the type of position that was held, and the potential position at Premera.

Before interviewing or making a job offer to a former or current government employee, work with Employee Experience to determine if their previous government employment could be a conflict of interest. See Hiring Current or Former Government Employees policy.

Federal and state healthcare programs have strict reporting requirements. All proposals, budgets, financial data, and reports created as part of these programs must be accurate, complete, and subject to appropriate management review. Supporting records must be retained in accordance with our record retention requirements. Anyone submitting false data to the government could face severe sanctions.

These requirements also apply to time reporting and expense reports. Specific rules cover what costs may be charged and how they can be allocated. Any costs charged to the government must be accurate and appropriately supported.

By following these reporting guidelines, we commit to maintaining integrity and accountability.

We take a cooperative approach when we receive reasonable requests from federal, state, and local authorities for information. For example, Premera may be asked for protected personal information (PPI) that is protected by federal and state privacy laws. In this case, we would be required to ensure that the agency is allowed to receive PPI. If possible, we may request special protection for the PPI.

Anyone who receives a request for information, either on our campuses or outside the workplace, must contact Regulatory Compliance & Ethics to help respond appropriately. Anyone who receives a request for employment information for acurrent or former Premera employee must contact Employee Experience. Communication with these departments helps us handle these requests correctly.

Employees and Board Members must complete Medicare Advantage compliance, fraud, waste, and abuse (FWA), and job-specific compliance training and education. We all have a duty to comply with the legal requirements of the Medicare Advantage program.

We are committed to complying with federal antitrust and state fair competition laws. We are forbidden from doing the following:

• Discuss pricing, bids, discounts, promotions, and costs with competitors
• Making agreements with competitors to allocate customers or divide markets (territories)
• Discriminating for or against customers on any basis other than underwriting criteria
• Making false or deceptive statements about our products or services

Before considering any type of arrangement with competitors, consult with Legal or Enterprise Vendor Management and Contracting.

As residents of this country, we enjoy the privilege of engaging in the political process. We encourage everyone to be active in this process, but all political activity must be conducted outside of working hours and away from our campuses.

All political activity and political contributions on behalf of Premera must be coordinated through Congressional and Legislative Affairs. Unless it is a Premera sponsored activity, employees must not act in the following ways:

• Represent or appear to represent Premera if they are not approved to do so.
• Seek payment or reimbursement of campaign contributions or fundraising costs.
• Use Premera property or employees for campaign activity. Examples include using our equipment to send invitations for fundraising events or assisting in a campaign during work hours.

All lobbying on behalf of Premera must be coordinated through Congressional and Legislative Affairs. Unless approved by the vice president of congressional and legislative affairs, employees must not do these things:

• Contact government officials about Premera’s position on legislation, regulations, or other policies.
• Represent or negotiate Premera’s position on developing legislative language to industry colleagues, trade associations, or other interested parties.

Q & A

Someone who said they are from the Office of the Insurance Commissioner (OIC) called me at work today and asked a bunch of questions about one of our new products. I didn’t know who it was so I told them I’d have to call them back. Was that okay?

Yes, that was the appropriate action to take. Whenever you receive a request from someone stating that they are from a state or federal insurance department, you must refer the call to Regulatory Affairs unless you have been authorized to answer inquiries previously. Please contact Legal or Regulatory Affairs for additional assistance.

Our reputation is one of our most valuable assets. To protect it, Corporate Communications oversees all contact with the media. If someone from a media organization contacts you seeking Premera’s position on an issue, policy, or practice, do not makeany comments. Refer them to Corporate Communications. All news releases concerning Premera must be approved by Corporate Communications. For more information about interacting with the media, contact Corporate Communications.

Third parties have an interest in leveraging their relationship with Premera and will occasionally ask for endorsements or permissions to use our trade names and logos. We have strict guidelines on these actions and any requests from third parties must be reviewed and approved by our Brand Creative and Legal departments in advance of any such use.

For more information about interacting with the media, please contact Corporate Communications at: CorpComm@premera.com.

• Fraud – Intentionally submitting false information in order to get money or a benefit.
• Waste and Abuse – Requesting payment for items and services when there is no legal entitlement to payment. Unlike fraud, the provider might not have knowingly and/or intentionally misrepresented facts to obtain payment.

• Does the prescription look altered or possibly forged?
• Have you filled numerous identical prescriptions for this beneficiary, possibly from different doctors?
• Is the person receiving the service or picking up the prescription the actual beneficiary (identity theft)?
• Is the prescription appropriate based on the beneficiary’s other prescriptions?
• Does the beneficiary’s medical history support the services being requested?

• Does the provider write for diverse drugs or primarily only for controlled substances?
• Are the provider’s prescriptions appropriate for the member’s health condition (medically necessary)?
• Is the provider writing for a higher quantity than medically necessary for the condition?
• Is the provider performing unnecessary services for the member?
• Is the provider’s diagnosis for the member supported in the medical record?
• Does the provider bill the sponsor for services not provided?

• Are the dispensed drugs expired, fake, diluted, or illegal?
• Do you see prescriptions being altered (changing quantities or Dispense As Written)?
• Are proper provisions made if the entire prescription cannot be filled (no additional dispensing fees for split prescriptions)?
• Are generics provided when the prescription requires that brand be dispensed?
• Are pharmacy benefit managers (PBMs) being billed for prescriptions that are not filled or picked up?
• Are drugs being diverted (drugs meant for places such as nursing homes or hospice being sent elsewhere)?

• Is the wholesaler distributing fake, diluted, expired, or illegally imported drugs?
• Is the wholesaler diverting drugs meant for nursing homes, hospices, and AIDS clinics and then marking up the prices and sending them to other smaller wholesalers or to pharmacies?

• Does the manufacturer promote off-label drug usage?
• Does the manufacturer provide samples, knowing that the samples will be billed to a federal healthcare program?

• Does the sponsor offer cash inducements for beneficiaries to join the plan?
• Does the sponsor lead the beneficiary to believe that the cost of benefits are one price, when the actual costs are higher?
• Does the sponsor use unlicensed agents?
• Does the sponsor encourage or support inappropriate risk adjustment submissions?

• Assets – Means equipment, company property and buildings, inventory, corporate funds, supplies, concepts, business strategies and plans, financial data, records and work files, employees’ work time, intellectual property, and other confidential information about the business and our customers.
• Fraud – Means the intentional, false representation or concealment of material fact(s) or information.

• Forgery or intentional alteration of a check, bank draft, or other financial document belonging to or issued by the company.
• Falsification of claims, time sheets, expense reports, financial or other business reporting documents, or employment records or reports.
• Anomalies in documents and financial statements.
• Unusual situations or reports involving unexpected amounts, frequencies, people, places, and times.
• Misappropriation of funds, securities, supplies, or other assets.
• Intentional mishandling or misreporting of money or financial transactions.
• Preparation of intentionally misleading or false financial statements.