Compliance Program

Banner University Health Plans (BUHP) is committed to ethical and legal conduct. This includes meeting the obligations of a programs involving the delivery of health care services. BUHP is a Medicare and Medicaid participant.
A key component of our commitment to meeting our obligations under these governmental programs and contractual relationships includes adopting standards that uphold these principles, which is the basis for this Compliance Program. The Compliance Program is described in several documents including the Code of Conduct, policies and procedures, as well as the Fraud, Waste, and Abuse Plan.
All employees and the Governing Bodies as well as first tier, downstream and related entities, subcontractors, Providers and agents (Business Partners) must make a personal commitment to adhere to the Code of Conduct.


Please review our Compliance Program and Fraud, Waste and Abuse Plan (January 1st through December 31st), which includes the BUHP code of conduct.


Banner University Health Plans is committed to compliance and meeting requirements of all applicable laws and regulations of CMS and AHCCCS. As part of our compliance program, please review the 2019 FDR Guide to help ensure your compliance with CMS, AHCCCS, and BUHP requirements.

Annual Attestation and Disclosure Statement

Contracted providers and Subcontractors, with Banner University Health Plans (BUHP) are required to complete the Annual Attestation and Disclosure Statement. 


1. Review each section

  • Section 1: Medicare and Medicaid Participation Compliance Program Requirements
  • Section 2: Attestations
  • Section 3: Organization Information and Signature

2. Complete the 2019 Annual Attestation online here: 

*If you are unable to complete the online form above, below is the PDF version.

2019 Annual Attestation Form

3. Complete the Offshore Subcontracting Attestation if contracting with offshore entity.

  Offshore Subcontracting Attestation

Required Trainings

BUHP General Compliance and FWA training is now available on our website. FDRs can take our training or a comparable training. FDRs are required to complete an attestation and submit it to BUHP indicating that the employees involved in the administration of Medicare Part C and D benefits have satisfied the training requirement. For FDRs (Subcontractors) under the Medicaid line of business, the following are required training elements:

a.   Detailed information about the Federal False Claims Act,

b.   The administrative remedies for false claims and statements,

c.   Any State laws relating to civil or criminal liability or penalties for false claims and statements, and

d.   The whistleblower protections under such laws.

Documentation of internal training can be through an individual certificate or a list showing the information for all of those who completed it through the internal web-based training.

The Compliance Departments or Vendor Oversight Staff track completion of training by FDRs through the completion and collection of annual attestations from all FDRs.

2019 General Compliance Training for FDRs

Code of Conduct

The Code of Conduct states BUHP’s over-arching principles and standards by which BUHP operates and defines the underlying framework for the compliance policies and procedures. Staff, Providers, and Business Partners, from the top to the bottom of BUHP’s organization, have the responsibility to perform their duties in an ethical manner in compliance with laws, regulations and BUHP’s policies.

BUHP requires that all FDRs supporting the Medicare Advantage and Part D Prescription Drug Program adopt and abide by the BUHP Code of Conduct or implement a Code of Conduct that incorporates standards of conduct and requirements consistent with BUHP’s Code of Conduct.

All BUHP Staff and Business Partners must read the Code of Conduct annually and sign an acknowledgement that they agree to abide by the Code of Conduct.

Related Documents

Code of Conduct

Compliance Department Contacts

Contact our Compliance Department with any questions and/or to report potential compliance issues and fraud, waste, and abuse.

ComplyLine (Confidential and Anonymous):

(888) 747-7989 (24 hours a day/7 days a week)



Banner University Health Plans

Compliance & Audit Department

2701 E. Elvira Road

Tucson, AZ 85756


(520) 874-7072

Compliance Officers:

Terri (Theresa) Dorazio, MS, CHC, CHPC, CPC

Director of Compliance

BUHP Medicaid Compliance Officer

(520) 874-2847


Linda Steward, CHC

Compliance Program Director

BUHP Medicare Compliance Officer

(520) 874-2553

Fraud, Waste, & Abuse

BUHP is committed to preventing Fraud, Waste, and Abuse (FWA).

If you suspect a provider or member of fraud and abuse, please contact us at any of the following methods:


  • Customer Care Center: (877) 874-3930; TTY users should dial 711.

  • ComplyLine (anonymous): (888) 747-7989; 24 hours a day/7 days a week.



Banner University Health Plans
Compliance and Audit Department
2701 E. Elvira Road
Tucson, AZ 85756


(520) 874-7072


Report Fraud, Waste, and Abuse Form


Reporting to AHCCCS 

Instances of suspected FWA shall be reported to AHCCCS OIG directly at:

Provider Fraud

To report suspected fraud by medical provider, please call the number below:

Member Fraud

To report suspected fraud by an AHCCCS member, please call the number below:


If you have questions about AHCCCS fraud, abuse of the program, or abuse of a member, please contact the AHCCCS OIG.


Fraud and Abuse Examples

Examples of Member Fraud and Abuse include but are not limited to:

  • Lending or selling your AHCCCS Identification Card to anyone.
  • Changing prescriptions written by any BUCA provider.
  • Giving incorrect information on your AHCCCS application.
  • Providing false materials or documents.
  • Leaving out important information.

Examples of Provider Fraud and Abuse include but are not limited to:

  • Use of the Medicaid system by someone who is inappropriate, unqualified, unlicensed or has lost their license.
  • Providing unnecessary medical services leading to unnecessary costs to the program.
  • Charging for medical services not rendered.
  • Not meeting professional standards for health care.

The Banner University Health Plans (BUHP) Compliance Department has been conducting routine provider medical record audits through random selection. These audits are required by AHCCCS but apply to all lines of business. This audit compares medical record documentation to the claims submitted and paid by BUHP to ensure both are proper and accurate.

The Auditors have identified similar errors in multiple audits and some of the types of errors observed include the following:

The Top Four Commonly Seen Errors:

  1. Progress notes not signed appropriately – progress notes are required to be signed and dated by the rendering/treating provider after each appointment and/or procedure prior to being billed.  What we see are notes that say pending; notes that are signed up to a year later; notes that are signed by someone on behalf of the provider or notes with no signature or date.  These examples make the note invalid. 
  2. Services billed under the NPI of a provider who did not render the service for an AHCCCS service.  For AHCCCS, providers are required to bill the claim under the NPI of the provider who rendered the service. Incident-to-services that are allowed under Medicare for Mid-levels to bill under a supervising physician is not allowed under AHCCCS.  The PA and NP must be registered with AHCCCS and credentialed. If it is not billed under the rendering provider, the claim is null and void. 
  3. Upcoding of Evaluation and Management Services – Coding Guidelines require medical documentation to support the proper evaluation and management code billed.  What we see in practice, is that the provider’s progress note does not support the level of service billed. Frequently, we are hearing that providers are using auto-fill and auto-prompts to facilitate and improve documentation, coding and billing. If used inappropriately, these tools can suggest a higher billing code than the actual services furnished warrant.  
  4. Diagnoses Codes Present on the Assessment And Not Billed – Many times the provider utilizes diagnoses codes in their assessment and these codes are not billed on the claim.  The diagnoses codes on the progress notes should be utilized for billing. 

If you have any questions regarding the errors and trends, please contact us by email at:


BUHP has written policies in place to:

  • Articulate our commitment to comply with all applicable Federal and State standards;
  • Describe compliance expectations as embodied in the Standards of Conduct;\
  • Implement the operations of the Compliance Program;
  • Provide guidance to Staff and Business Partners on dealing with suspected, detected or reported compliance issues;
  • Identify how to communicate compliance issues to appropriate compliance personnel;
  • Describe how suspected, detected or reported compliance issues are investigated and resolved by our company; and
  • Include a policy of non-intimidation and non-retaliation for good faith participating in the Compliance Program, including, but not limited to reporting potential issues, investigating issues, conducting self-evaluations, audits and remedial actions, and reporting to appropriate officials

FDR Newsletters

BUHP provides our network providers with our FDR newsletter quarterly. Providers can find helpful information and updates about our compliance program and policies.