Additional Docs - Criteria and Capacity.pdf

Capacity, Proposed Solution & Approach

Prepared by Talisman Solutions Inc.

Contents Company Overview

About Talisman Solutions

Core Competencies

Why Talisman Solutions

Experience & Capacity

Subject Matter Experience

Capacity to Deliver

Solution Highlights

Proposed Solution & Process Flow

Proposed Process

Phase 1: Initial Setup and System Integration

Phase 2: Claim Identification and Data Collection

Phase 3: Data Validation and Error Correction

Phase 4: Reporting to CMS

Phase 5: Post-Reporting Management and Compliance Oversight

Quality Assurance

Service Level Agreement (SLA)

Solution Differentiators

Roles & Responsibilities

Client Responsibilities

Talisman Solutions Responsibilities

Roles & Responsibilities (RACI Metrics)

Compliance Statements

Company Overview

About Talisman Solutions

Founded in 2004, Talisman Solutions is a trusted provider of healthcare revenue cycle management, compliance, and reporting services for healthcare providers, insurers, and government entities across the United States. With more than two decades of experience, we have developed a reputation for delivering accurate, reliable, and timely solutions that meet the highest compliance standards.

Core Competencies

• Medicare and Medicaid compliance reporting, including Section 111 MSP reporting.

• Revenue cycle management and medical billing services across multiple specialties.

• Data integration and system interoperability using API and flat file exchange.

• Strong track record of working with state agencies, providers, and payers.

• Commitment to affordability, transparency, and long-term partnerships.

• Best in class Healthcare AI and Technology capabilities.

Why Talisman Solutions

• Over 21 years of healthcare compliance experience.

• Skilled staff trained in CMS reporting rules and requirements.

• Secure IT infrastructure with adherence to HIPAA and NIST security standards.

• Proven ability to deliver accurate reporting accepted by CMS.

• Client support and training

Talisman Solutions brings the knowledge, capacity, and infrastructure necessary to ensure the Industrial

Commission of Arizona receives accurate and compliant MSP reporting services under this solicitation.

Experience & Capacity

Talisman Solutions has over 20 years of healthcare compliance and claims reporting expertise. While we have not directly served as a Section 111 reporting agent, our team has extensive experience in compliance-driven medical billing, CMS data exchange, and error-free claims reporting — capabilities directly transferable to ICA’s requirements.

Subject Matter Experience

Area Capabilities & Achievements

Healthcare Compliance Over 20 years of HIPAA-driven revenue cycle management and claims reporting.

CMS Familiarity Deep knowledge of CMS reporting formats and compliance rules; >99% accuracy in prior CMS-facing submissions.

Workers’

Compensation (WC)

Supported state-level WC programs with data validation, claims reconciliation, and compliance reporting.

Technology Integration Proven ability to integrate with payer/provider systems via API, SFTP, and flat file exchange.

Data Accuracy Consistently achieved ≥99% accuracy across millions of claims processed.

Capacity to Deliver

Resource Area Talisman Capacity

Compliance Specialists Dedicated team trained in CMS rules and Section 111 understanding and expertise.

Technical Integration

Team

Skilled in ETL, API, and flat file workflows with secure transmission.

Account Management Single point of contact for ICA, supported by compliance lead and QA analyst.

Scalability Ability to increase staff/resources within 30 days to meet ICA’s needs.

Security Infrastructure Fully HIPAA-compliant, NIST & State RAMP-aligned U.S.-based operations.

Solution Highlights Talisman Solutions will deliver Mandatory Section 111 MSP Reporting Services through a structured, reliable, and fully compliant process tailored to the Industrial Commission of Arizona’s needs.

Data Integration and Reporting

• Integration with ICA’s Special Fund Claims System (File Handler) via flat file exchange or secure

API, based on ICA’s preference.

• Reporting data will be received in the specified format and validated before submission.

• Each quarterly submission will undergo an internal compliance review to ensure CMS acceptance.

• Technical Solution

Data Validation & Processing Tools- Data validation is the process of ensuring that data is clean, correct, and useful. It verifies that the data input meets certain rules or standards.

Goals:

• Ensure data accuracy and integrity.

• Prevent bad or inconsistent data from entering systems.

• Catch errors early.

Tooling:

• Missing Query Data – Identify claims lacking essential demographic information like Date of

Birth, SSN etc.

• Eligibility Data Mismatch – a feature to flag discrepancies between ICA’s data and Medicare query responses for potential updates.

• Missing Data Smart Search – To address incomplete data, we utilize third parties to obtain missing data points that are crucial for compliance.

AI Integration

• Analyze data.

• Make predictions.

• Automate tasks.

• Interact with users intelligently.

Compliance with CMS Requirements

• All submissions will strictly follow CMS Section 111 reporting rules, including file layouts, field-level requirements, and submission timelines.

• Our compliance team will monitor CMS updates and incorporate any changes into reporting processes to keep ICA aligned with federal regulations.

User Interface and Accessibility

• User-friendly portal: a secure web-based portal with intuitive data management tools and reports.

• Comprehensive Reporting & Analytics: robust reporting capabilities and analytical tools

• Dashboard: for compliance oversight, query statistics, and PAID Act data.

• Training & Support: educational webinars, targeted training modules for claims teams, and ongoing support for compliance officers and staff.

Accuracy and Audit Trail

• Use of proprietary AI engine logic identifies potential errors before official submission, providing time for correction and avoidance of penalties.

• All reports will be validated through automated checks and manual reviews before submission to CMS.

• CMS acceptance reports will be documented and provided to ICA for auditing purposes.

• Any discrepancies identified will be promptly corrected and resubmitted.

Adaptability and Futureproofing

• Capability to quickly adapt to evolving CMS standards, new policies, and legislative changes.

• Provision of testing environment to prepare for upcoming changes

Ongoing Support and Communication

• Talisman Solutions will assign a dedicated team to ICA as the primary point of contact for reporting, billing, and issue resolution.

• We will be available for scheduled meetings, quarterly reporting reviews, and ad-hoc inquiries as required by ICA.

Billing and Payment

• In alignment with the RFQ requirements, services will be billed quarterly on a fixed-rate basis.

• Transparent invoicing will include all required details with no hidden charges or additional fees.

Security and Data Protection

• All data will be handled within the United States, in compliance with state requirements prohibiting offshore performance.

• Systems and processes will adhere to HIPAA, NIST Low/Moderate Impact security controls, and

State RAMP standards as applicable.

Adaptability

By combining proven technical capabilities, a strong compliance framework, and reliable client support, Talisman Solutions will ensure the Industrial Commission of Arizona receives accurate, timely, and fully compliant Section 111 MSP reporting services.

Proposed Solution & Process Flow Please see below the Talisman Solutions’ process flow for Mandatory Section 111 Medicare Secondary

Payer (MSP) Reporting for the Industrial Commission of Arizona (ICA), Special Fund Division. We ensure that the Centers for Medicare & Medicaid Services (CMS) can properly determine primary and secondary payer responsibility, ensuring Medicare appropriately pays for services and facilitates the recovery of conditional payments.

Proposed Process

Phase 1: Initial Setup and System Integration

1. RRE Registration and Profile Recertification:

o The vendor ensures the ICA is properly registered as a Responsible Reporting Entity

(RRE) with CMS.

o Manage the annual recertification of the RRE Profile Report to maintain active status and avoid deactivation of the RRE ID, which would prevent file submissions and lead to non-compliance.

2. IT System Integration:

o Establish secure data exchange between the vendor's system and the ICA's File Handler claims system. This integration must support flat file import/export or an API call.

o The vendor provides ICA with the format for screenshots of how reporting data will be received from the File Handler.

Phase 2: Claim Identification and Data Collection

1. Medicare Eligibility Query:

o Perform monthly queries to determine Medicare beneficiary status for all claimants.

o Collect the "Big Five" data points for queries: Social Security Number (SSN) (or Health

Insurance Claim Number/Medicare Beneficiary Identifier), first name, last name, date of birth, and gender. Medicare requires a match on the SSN/MBI/HICN and at least three of the other four fields.

o Implement "Good Faith" Efforts for SSN Collection: If the SSN is unavailable, document at least three attempts to obtain it: one in writing, one by mail, and one by phone or email. Retain this documentation for a minimum of five years as a safe harbor against

Civil Money Penalties (CMPs).

o Process PAID Act Data: Extract and analyze Medicare Part C (Medicare Advantage) and

Part D (prescription drug) enrollment information returned in query response files for the last three years (up to 12 instances). Proactively address potential liens from these plans to avoid double damages lawsuits.

2. Ongoing Responsibility for Medicals (ORM) Evaluation:

o Evaluate and track ORM status for each claim. ORM indicates the carrier's ongoing responsibility for medical care and typically applies to workers' compensation and no-fault claims. The effective date of ORM is the date of injury.

o Identify ORM assumption: Report ORM when the carrier assumes responsibility for medical benefits, even if no payments have been made.

o Ensure proper handling of the Workers' Compensation ORM Exclusion for medical-only claims with limited lost time, payments directly to providers, and total medicals not exceeding $750.

3. Total Payment Obligation to Claimant (TPOC) Identification:

o Identify all TPOC events, which include settlements, judgments, awards, or other payments that resolve or partially resolve a claim.

o Report TPOCs exceeding the $750 threshold for liability, workers' compensation, and no-fault claims.

o Ensure accurate calculation of the TPOC amount, including Medicare-covered and non-covered medical expenses, indemnity, and attorney fees.

o Determine the correct TPOC date: This is generally the date the obligation is signed, or the date of court approval if required.

4. Collection of Specific Data Fields:

o Collect and maintain accurate ICD diagnosis codes related to the claim, ensuring against both over-reporting (unrelated codes) and under-reporting (missing related injuries). Update codes throughout the life of the claim.

o Collect new WCMSA data fields for workers' compensation settlements with Medicare beneficiaries, effective April 4, 2025: MSA Amount, MSA Period, Lump Sum or

Structured/Annuity Payout Indicator, Initial Deposit Amount, Anniversary (Annual)

Deposit Amount, Case Control Number (optional), and Professional Administrator EIN

(optional).

o Collect other required information such as RRE Tax Identification Number (TIN), RRE address, and cause codes.

Phase 3: Data Validation and Error Correction

1. Proactive Data Validation:

o Utilize proprietary logic to duplicate Medicare's validation rules and identify errors before submission to CMS. This reduces late reporting penalties and excessive errors.

2. Error Report Generation and Review:

o Generate easy-to-understand error reports (e.g., CW errors for WCMSA data).

o Provide expert oversight and assistance in reviewing and resolving identified errors.

3. Timely Correction of Errors:

o Address hard errors immediately, as they cause record rejections.

o Correct soft errors on the next file submission.

o Focus on common errors such as missing/incorrect ORM indicators, inaccurate ICD coding, improper ORM termination, and late SSN capture.

o Ensure consistency: Reconcile any discrepancies between Section 111 reported data and information provided to CMS recovery contractors to avoid penalties.

Phase 4: Reporting to CMS

1. Adhere to Quarterly Reporting Schedule:

o Submit claims quarterly within the assigned seven-day submission timeframe.

o Submit "empty files" quarterly if no payments are made, as CMS requires this once an

RRE is registered.

o Small volume submitters (under 24,000 records) may use the HTTPS (Secure Website) method.

2. Submit ORM Data:

o Report ORM when it is first assumed.

o Populate the ORM termination date when ORM ends, rather than changing the ORM indicator from 'Y' to 'N'. This defines the coverage period for Medicare's recovery efforts.

o Utilize CMS's criteria for ORM termination, including physician statements for "no further treatment is necessary," TPOCs fully resolving medicals, statute of limitations expiration, other state laws (e.g., Georgia's 400-week rule), exhaustion of no-fault limits, and specific "no practical likelihood of future medical treatment" criteria for long-open minor injury claims.

3. Submit TPOC Data:

o Report TPOCs, ensuring timeliness. Penalties may apply for TPOCs not reported within one year.

o Include WCMSA data for all workers' compensation TPOC reports, regardless of the

$25K voluntary review threshold, effective April 4, 2025.

o For $0 WCMSA situations (effective July 17, 2025, CMS will no longer review these proposals), ensure supporting documentation is maintained for potential audits.

4. Submit Amended Review Requests:

o Process Amended Review requests for WCMSA approvals at any time after a CMS decision, eliminating the previous 12-month waiting period, effective April 7, 2025. This allows for quicker challenges to CMS counter-higher and potential settlement reductions.

Phase 5: Post-Reporting Management and Compliance Oversight

1. Evaluate CMS Claim Response Files:

o Receive and analyze CMS claim response files within 45 days, reviewing disposition codes (e.g., 01=Accepted with ORM, 02=Accepted without ORM, SP=Rejected) and any error codes or compliance flags (e.g., late submission of TPOC/ORM termination).

2. Address Rejected Claims and Compliance Flags:

o Promptly correct and resubmit any rejected claims.

o Address compliance flags proactively to mitigate penalty risks.

3. Conditional Payment Recovery Management:

o Recognize that CMS uses Section 111 data to drive conditional payment recoveries through contractors like the Commercial Repayment Center (CRC) (for open ORM claims) and Benefits Coordination and Recovery Center (BCRC) (for post-settlement claims).

o Dispute unrelated conditional payments promptly and effectively. Failure to respond timely can lead to debts going to the Treasury, interest, and penalties.

4. Auditing and Reporting to ICA:

o Provide the ICA with information on reporting frequency and accepted reports for their auditing purposes.

o Offer management reports and analytics (e.g., CMP readiness dashboard, query/reporting statistics, PAID Act data) to ensure holistic compliance oversight and actionable insights.

5. Ongoing Training and Best Practices:

o Conduct regular training for ICA claims handlers, paralegals, and compliance officers on

MSP reporting best practices and evolving CMS guidance.

o Assist ICA in establishing and refining internal best practices for data management and integrity, ensuring continuity across staff and departments.

This comprehensive process aims to ensure the ICA's compliance with Section 111 reporting requirements, minimize risks of penalties, and optimize their Medicare Secondary Payer obligations.

Quality Assurance

QA Stage Description Owner Output

Data Validation Automated checks on claimant demographics, ICD codes, and policy details.

Compliance

Specialists

Clean, error-free dataset

Pre-Submission

Review

Manual review of sample Cases to verify accuracy.

QA Lead Verification report

Test Submission Trial run on CMS test environment (if applicable).

Technical Team CMS feedback & error log

Final

Submission

Upload of validated file to CMS

COBSW/SFTP portal.

Reporting Team CMS confirmation

Audit Log Documentation retained for 7 years for audit readiness.

Compliance

Team

Audit trail & proof of submission

Service Level Agreement (SLA)

Service Component SLA Commitment

Quarterly Report Submission 100% of reports submitted on or before CMS deadlines

Accuracy Rate ≥ 99% first-pass CMS acceptance rate

Error Correction All CMS rejections corrected & resubmitted within 5 business days

Response Time Acknowledgment of ICA inquiries within 5 business hours

Issue Resolution Critical issues resolved within 1 business day standard issues within 5 business days

Data Security 100% compliance with HIPAA, NIST, and State RAMP controls

Uptime ≥99% system availability for file processing and reporting

Solution Differentiators

Talisman Solutions offers a unique combination of expertise, compliance, and client-focused service delivery that distinguishes us from other vendors. Our proposal is designed to not only meet the

Industrial Commission of Arizona’s requirements but also provide added value through the following key differentiators:

1. Proven Compliance Expertise

• Nearly two decades of experience in healthcare compliance, with a strong focus on Medicare

Secondary Payer (MSP) and CMS reporting requirements.

• Demonstrated success in achieving CMS acceptance on first submission, minimizing rework and compliance risks.

2. Seamless System Integration

• Skilled in working with diverse claims systems, including flat file and API-based integration methods.

• Ability to customize reporting processes to align with ICA’s File Handler system for efficient and secure data exchange.

3. Robust Quality Assurance

• Comprehensive internal review processes that combine automated validation with manual oversight.

• Guaranteed audit-ready documentation for every report submitted to CMS.

4. Dedicated Client Support

• Assignment of a single point of contact for ICA to ensure streamlined communication and accountability.

• The management team is available for quarterly reviews, ad-hoc inquiries, and rapid resolution of issues.

5. Commitment to Security and Confidentiality

• U.S.-based data Storage & handling.

• Adherence to HIPAA, NIST security standards, and State RAMP cybersecurity guidelines.

• Strict confidentiality protocols protect claimant and beneficiary data at all times.

6. Cost-Effective and Transparent Pricing

• Fixed quarterly billing model with no hidden fees or unexpected charges.

• Competitive pricing is designed to deliver maximum value within ICA’s budget constraints.

By selecting Talisman Solutions, the Industrial Commission of Arizona will gain a reliable partner with the expertise, infrastructure, and client-first approach needed to ensure successful Section 111 MSP reporting throughout the contract term.

Roles & Responsibilities

Client Responsibilities

To ensure compliance with Mandatory Section 111 Medicare Secondary Payer (MSP) Reporting Services for the Industrial Commission of Arizona (ICA), Special Fund Division, a clear delineation of responsibilities between the client and the vendor is essential. The ICA, as the Responsible Reporting

Entity (RRE), holds the ultimate responsibility for compliance and accurate data submission, regardless of whether a vendor is used for reporting. Critical responsibilities include:

Data Provision and Accuracy:

• Obtain and Provide "The Big Five" Data: The ICA must obtain and provide essential claimant demographic data for Medicare beneficiary identification, which includes: First Name, Last Name, Gender, Date of Birth, and Social Security Number (SSN), Health Insurance Claim Number (HICN), or

Medicare Beneficiary Identifier (MBI) (or in some instances, the last five digits of the SSN). Without this, querying eligibility or reporting is impossible.

• Document "Good Faith" Efforts for SSN Collection: If an SSN cannot be obtained, the ICA must adhere to CMS's "good faith" compliance criteria to avoid penalties. This involves:

• Communicating the need for "The Big Five" data points to the individual and their attorney/representative.

• Requesting this information at least three times: once in writing (including email), once more by mail, and once more by phone or other means if no response to mailings.

• Retaining documentation of these efforts (including any written rejection) for a minimum of 5 years.

• Ensure Accurate Claim Details: Provide precise, up-to-date details including accurate diagnosis codes

(ICD codes), correct settlement amounts, and accurate date of injury/exposure. Diagnosis codes must be relevant to the claim, avoiding both over-reporting unrelated codes and under-reporting compensable injuries.

• Report Workers’ Compensation Medicare Set-Aside Arrangement (WCMSA) Data: For Workers’

Compensation settlements involving a Medicare beneficiary, the ICA must provide specific WCMSA data fields: MSA Amount, MSA Period, Lump Sum or Structured/Annuity Payout Indicator, Initial

Deposit Amount, Anniversary (Annual) Deposit Amount, Case Control Number (optional), and

Professional Administrator EIN (optional). If there is no WCMSA, enter all zeros for the MSA

Amount. When multiple defendants are party to a single settlement, the ICA is required to report the total MSA value, not just its proportionate share.

Timely Reporting and Updates:

• Adhere to Quarterly Reporting Schedule: Claims must be submitted quarterly, within a specific 7-day reporting schedule assigned by CMS. The ICA's internal processes must support this frequency.

• Timely TPOC Reporting: The ICA must report a Total Payment Obligation to Claimant (TPOC) within one year from its date. While quarterly reporting is best practice, CMS allows this grace period. The

TPOC date is generally the date the obligation is signed, or the date of court approval if required.

• Timely ORM Reporting and Termination: The assumption of Ongoing Responsibility for Medicals

(ORM) should be reported at the onset of a claim where such responsibility is established. ORM termination dates must also be reported promptly to define the coverage period for Medicare's recovery efforts. This is done by entering a specific termination date, not by changing the ORM flag from 'Y' to 'N'. Termination criteria include a physician's statement indicating no future treatment, a settlement fully resolving medicals, statutory limitations, or specific new criteria provided by CMS.

Administrative claim closure alone is not sufficient to terminate ORM.

• Correct Errors Promptly: All reporting errors must be addressed and corrected in a timely manner.

Failure to correct errors is considered as if the data was never reported, which can lead to penalties.

• Re-query Medicare Status for MA Plans: Medicare Advantage (MA) plans can change yearly, so the

ICA should consider re-querying Medicare beneficiary status to capture the most current MA plan enrollment information.

• Consistency in Reporting: Responses to Medicare's recovery efforts must not contradict Section 111 reporting. Discrepancies can lead to penalties.

Compliance and Internal Management:

• Register as an RRE: The ICA must register for Section 111 reporting and fully test data exchange with

CMS.

• Annual RRE Profile Report Recertification: Annually recertify the RRE Profile Report to ensure CMS has proper contact information; failure to do so can lead to deactivation of the RRE ID.

• Train Personnel: Regularly train claims handlers, paralegals, and compliance officers on MMSEA

Section 111 reporting best practices and changes in CMS guidance.

• Establish Best Practices: Implement clear best practices for data management and integrity across the organization.

• Maintain Documentation and Audit Trails: Store copies of all submission confirmations, query responses, and audit logs securely, and document all CMS and BCRC communications.

• Adhere to File Submission Instructions: When uploading Excel files for quotation forms, do not change other parts of the file or the structure of the answer grids, as this could prevent proper data import.

• Monitor New Requirements: Proactively monitor and adapt to new reporting requirements, such as

WCMSA data fields which become prospective for records submitted on or after April 4, 2025.

Talisman Solutions Responsibilities

The vendor providing Section 111 MSP Reporting Services acts as an agent for the ICA, assisting with the complex reporting requirements and technical execution. Key responsibilities include:

Data Management and Reporting Execution:

• Perform Monthly Medicare Query Process: Conduct monthly queries to determine Medicare beneficiary status, including returning Medicare Advantage (Part C) and Part D prescription drug coverage information.

• Submit Quarterly Claim Files: Electronically submit claim information to CMS quarterly, adhering to the assigned 7-day reporting schedule. The vendor's processes must ensure acceptance by CMS.

• Ensure Data Quality and Error-Free Reporting: Implement proactive data validation to ensure reporting accuracy, aiming for error-free submissions.

• Provide Timely Error Reports and Support: Deliver clear, easy-to-understand error reports and assist the ICA with timely error management and resolution, as uncorrected errors are considered non-reported by CMS.

• Interface with Agency Systems: Be capable of interfacing with ICA's systems through flat file import/export or an API call, providing the necessary data exchange and potentially screenshots of how the data would look in the ICA's claims system.

• Support New Reporting Fields: Ensure systems and processes are updated to capture and report new data fields, such as WCMSA information, by their effective implementation dates.

• Assist with Missing Data: Offer services to obtain missing SSN and Date of Birth data points to ensure compliance and avoid reporting delays.

Compliance Guidance and Support:

• Provide MSP Expert Oversight: Offer hands-on MSP expert oversight to ensure accurate, timely, and complete reporting to Medicare.

• Ongoing Education and Training: Provide ongoing education and training on Section 111 compliance, industry updates, and best practices for the ICA's staff.

• Stay Informed on CMS Updates: Continuously monitor and integrate changes in CMS guidance and new reporting requirements into their services and advise the ICA accordingly.

• Ensure Data Security: Utilize CMS-approved, encrypted reporting platforms and adhere to robust IT security policies for data in transit and at rest.

• Audit Services: Offer audit services to review the ICA's Section 111 data and claims information to identify potential gaps or compliance issues.

• Conditional Payment Resolution Support: Offer services for Medicare conditional payment identification and resolution, including for Medicare Advantage (Part C) and Part D prescription drug plans, proactively communicating with these plans to resolve liens and avoid double damages lawsuits.

• Dedicated Support: Assign a dedicated Electronic Data Interchange (EDI) Representative to assist with technical questions and the reporting process.

Roles & Responsibilities (RACI Metrics)

Requirement/Task Vendor ICA CMS Medicare Advantage/Part D plans

RRE Registration and Annual Profile Report Recertification

R A I N/A

Medicare Beneficiary Identification (Query Process)

R A I N/A

Obtaining "Big Five" Data Points C A N/A N/A

Ongoing Responsibility for Medicals (ORM) Reporting

R A I N/A

ORM Termination Reporting R A I N/A

Total Payment Obligation to Claimant (TPOC) Reporting (including WCMSA Data)

R A I N/A

Timely Submission of Quarterly Reporting R A I N/A

Error Management and Correction R A I N/A

Compliance with CMS Guidance R A N/A N/A

Maintenance of Documentation and Audit Trails C A I N/A

Avoiding Civil Money Penalties (CMPs) C A I N/A

Engagement with Medicare Advantage/Part D Plans (Post-PAID Act)

R A N/A I

Training and Education R A N/A N/A

Interface with Claims System (File Handler) R A N/A N/A

Invoice Payment N/A A N/A I

Compliance Statements

Talisman Solutions affirms its full compliance with all requirements outlined in Solicitation No.

BPM007093. Our organization is prepared to meet and maintain all mandatory conditions for the duration of the contract.

1. CMS and Section 111 Compliance

• We comply fully with Section 111 of the Medicare, Medicaid, and SCHIP Extension Act of 2007.

• Our reporting processes align with CMS technical specifications and are updated promptly to reflect changes issued by CMS.

2. Insurance Requirements

• Talisman Solutions maintains active insurance policies that meet or exceed the limits required under this solicitation, including:

o Commercial General Liability (CGL) coverage o Business Automobile Liability coverage o Workers’ Compensation and Employers’ Liability coverage o Professional Liability coverage

• A Letter of Insurability (Exhibit F) will be provided as required.

3. State Procurement Compliance

• We acknowledge and accept the Arizona Procurement Code (A.R.S. Title 41, Chapter 23; A.A.C.

Title 2, Chapter 7).

• We agree to the Uniform Terms and Conditions and Special Terms and Conditions of the solicitation.

• We will submit all mandatory Exhibits (A–F) and pricing information as required.

4. Security and Confidentiality

• All work will be performed within the United States, in compliance with Arizona’s prohibition on offshore data handling.

• Talisman Solutions adheres to HIPAA, NIST Low/Moderate Impact security controls, and State

RAMP guidelines.

• Confidential claimant and beneficiary information will be protected in accordance with federal and state privacy laws.

5. Employment and Labor Compliance

• We comply with the Federal Immigration and Nationality Act and E-Verify requirements (A.R.S. §

41-4401).

• We certify compliance with A.R.S. § 35-394 regarding the prohibition on the use of forced labor of ethnic Uyghurs.

• We certify that Talisman Solutions is not engaged in, and will refrain from, any boycott of Israel as defined in A.R.S. §§ 35-393 et seq.

6. Business Standing and Licenses

• Talisman Solutions maintains all required federal, state, and local licenses and permits necessary to operate.

• We are in good standing and fully authorized to conduct business in the United States.

7. Technology and AI Restrictions

• We affirm compliance with the State’s restrictions on Artificial Intelligence (AI) use, including prohibitions on unauthorized generative AI queries or model training using State data.

Through these compliance commitments, Talisman Solutions ensures that all contractual, regulatory, and legal obligations will be met without exception.