Prohibition on plan delegation of liability to subcontractor 

AZ | AZBH | CA | CO | CT | DC | FL | FLMH | GA | HI | HIBH | IL | IN | IA | IABH | KS | KY | ME | MD | MA
MABH | MN | MO | MT | NE | NEBH | NH | NJ | NM | NY | NC | ND | OH | OK | OR | ORMH | PA | RI
SC | TN | TX | UT | UTMH | VA | WA | WV | WI


AZ

"51.  SUBCONTRACTS
The Contractor shall be legally responsible for contract performance whether or not subcontracts are used.  No subcontract shall operate to terminate the legal responsibility of the Contractor to assure that all activities carried out by the subcontractor conform to the provisions of this contract…"  Arizona Contract, page 49.

AZBH

"43.  SUBCONTRACTS
ADHS shall be legally responsible for contract performance whether or not subcontracts are used.  No subcontract shall operate to terminate the legal responsibility of ADHS to assure that all activities carried out by the subcontractor conform to the provisions of this contract...

44.  SUBCONTRACTOR COMPLIANCE WITH CONTRACT REQUIREMENTS
ADHS shall be held fully liable for the performance of all contract requirements and shall develop and maintain a system for regular and periodic assessment of all its subcontracted RBHAs' compliance with its terms.  ADHS shall advise AHCCCSA in writing within five working days of any subcontracted RBHA non-compliance and of the corrective measures taken, including the amount and duration of sanctions, to ensure subsequent compliance."  Arizona Behavioral Health Contract, pages 34-35.

CA

"6.5  QUALITY IMPROVEMENT SYSTEM
6.5.1   General Requirement...
The Contractor will be accountable for the quality of health care delivered whether it be preventive, primary, specialty, emergency, or ancillary care services regardless of the number of contracting and subcontracting layers between the Contractor and the individual practitioner delivering care to the Member."  California Contract, page 86.

"6.5.2.6  Delegation of QIP Activities
The Contractor is accountable for Quality Improvement even when it delegates Quality Improvement activities to its subcontractors."  California Contract, page 89.

"6.5.5.7 Continuing Oversight
The Contractor will remain responsible for the oversight and monitoring of delegated Facility review activities."  California Contract, page 95.

"6.8.2   Liability
The Contractor is responsible for all Marketing activity conducted on behalf of the Contractor.  Contractor will be held liable for any and all violations by any Marketing Representatives."  California Contract, page 133.

CO

"X. SUBCONTRACTS
A. The Contractor shall be responsible for all work performed under this Contract, but may, with the approval of the Department, enter into subcontracts for the performance of work required under this Contract. No subcontract which the Contractor enters into with respect to performance under the Contract shall in any way relieve the Contractor of any responsibility for the performance of duties under this Contract.

B… If the Contractor delegates administrative activities to a Subcontractor, the Contractor shall prepare a written description of the subcontracted activities, accountability, frequency of reporting, and evaluation. The Contractor must maintain direct responsibility of the activity, and must be able to show evidence of the Subcontractor’s compliance during reviews and audits...

G. The Contractor shall be responsible to the Department to ensure that all activities under the subcontracts are carried out."  Colorado Contract, pages 38-39.

CT

"3.43 Subcontracting for Services...
The MCO shall be directly responsible and liable for all of the contractual provisions under this contract regardless of whether the MCO chooses to subcontract their responsibilities to a third party.  No subcontract shall operate to terminate the legal responsibility of the MCO to assure that all activities carried out by the subcontractor conform to the provisions of the contract…"  Connecticut Contract, pages 52-53.

DC

"ARTICLE IV - SUBCONTRACTS
A.   No subcontract shall terminate the legal obligation of Provider to ensure that all  activities carried out by the subcontractor conform to the provisions of this contract.  Subject to these conditions, any service or function required to be provided by Provider may be subcontracted to a qualified organization or person."  District of Columbia Contract, pages 34-35.

FL

"14.  Subcontracts.  The plan is responsible for all work performed under this contract, but may, with the written approval of the agency, enter into subcontracts for the performance of work required under this contract...

No subcontract which the plan enters into with respect to performance under the contract shall in any way relieve the plan of any responsibility for the performance of duties under this contract.  The plan shall assure that all tasks related to the subcontract are performed in accordance with the terms of this contract..."  Florida Contract, page 62.

FLMH

"4.18  Subcontracts...
No subcontract which the Contractor enters into with respect to performance under the contract resulting from the RFP shall in any way relieve the contractor of any responsibility for performance of its duties..."  Florida Mental Health RFP, page 61.

GA

"1.040  Use of Subcontractors...
  No subcontract shall in any way relieve the Contractor of any responsibility for the performance of all tasks defined in the Contract."  Georgia RFP, Appendix E, page 3.

HI

"6.  Subcontracts and Assignments.  The CONTRACTOR shall not assign or subcontract any of the CONTRACTOR's duties, obligations, or interests under this Agreement and no such assignment or subcontract shall be effective unless
  (i) the CONTRACTOR obtains the prior written consent of the STATE and
  (ii) the CONTRACTOR's assignee or subcontractor submits to the STATE a tax clearance certificate from the Director of Taxation, State of Hawaii, showing that all delinquent taxes, if any, levied or accrued under state law against the CONTRACTOR's assignee or subcontractor have been paid.  Additionally, no assignment by the CONTRACTOR of the CONTRACTOR's right to compensation under this Agreement shall be effective unless and until the assignment is approved by the Comptroller of the State of Hawaii, as provided in section 40-58, HRS."  Hawaii Contract, page 3.

"60.600 Subcontracts/Provider Agreements...
No subcontract or agreement which the offer enters into with respect to the performance under this contract shall in any way relieve the offer of any responsibility for any performance required of it by this contract…" Hawaii RFP, pages 78-79.

HIBH

"60.600  Subcontracts/Provider Agreements...
No subcontract or agreement which the offeror enters into with respect to the performance under this contract shall in any way relieve the offeror of any responsibility for any performance required of it by this contract…"  Hawaii Behavioral Health RFP, pages 68-69.

IL

"(s)  Subcontracts
The Contractor may furnish any Covered Services identified in Article V(b) or any obligations under this Contract by means of subcontractual relationships subject to the following conditions: ...
(3)  The Contractor shall remain responsible for the performance of the subcontractor;
(4)  No subcontract can terminate the legal responsibilities of the Contractor to the Department to assure that all the activities under this Contract will be carried out…"  Illinois HMO Contract, pages 47-48.

IN

"1.9   SUBCONTRACTING OBLIGATIONS
Although it is anticipated that any offeror who submits a proposal will perform the major portion of the duties as requested, subcontracting by the successful offeror for performance of any of the offeror's functions, whether described in the Request for Proposals, the offeror's proposal, or the contract between the successful offeror and the State, will be acceptable in performing the requirements of this RFP, as long as the successful offeror obtains the approval of the OMPP and IDOA before subcontracting any portion of the project's requirements.  The successful offeror is responsible for the performance of any obligations that may result from the RFP.  No subcontract terminates the legal responsibility of the successful offeror to the State to assume that all activities under the contract are carried out..."  Indiana RFP, page 1-11.

IA

"4.23  Subcontracts with Providers and Other Subcontractors
All subcontracts entered into by the HMO for the performance of any obligation under this Contract shall be in writing...
The HMO shall remain responsible for all services performed under this Contract…"  Iowa Contract, page 38.

IABH

"12.2 USE OF SUBCONTRACTORS FOR OTHERS THAN SERVICE PROVISION...
The Contractor will responsible for all work performed under the contract, whether or not subcontractors are used.  No subcontract into which the Contractor enters with respect to performance under the contractor will, an any way, relieve the Contractor of any responsibility for performance of its duties, and any sub-contract shall incorporate the terms of the Contract between the Departments and the Contractor."  Iowa Behavioral Health Contract, page 7.

"44.0  NETWORK MANAGEMENT
In managing provider network, the Contractor shall also meet the following requirements: ...
4)...All contracts with providers for special financial arrangements must be approved by the Departments prior to implementation.  Regardless of any sub-contractual arrangements, the Contractor shall remain solely responsible for compliance with the terms of this contract…"  Iowa Behavioral Health Contract, pages 29-30.

KS

"B.  SUBCONTRACTS
The HMO has the right to subcontract for services specified under this contract. Any subcontract into which the HMO enters with respect to performance under the contract shall in no way relieve the HMO of any responsibility for performance of its duties. SRS will consider the HMO to be the sole point of contact with regard to contractual matters, including payment of any and all charges resulting from the contract...

Subcontracts shall not terminate legal liability of the HMO under this contract…"  Kansas Contract, pages 80-81.

"D.  DELEGATIONS OF AUTHORITY
1.  HMO Contract, Page 2, Delegation of Authority.  The following modification applies:
The reference paragraph,
    No delegations of authority are permitted under this contract.
is deleted in its entirety and replace with the following:
    No delegations of authority are permitted under this contract, with the following exception:
        SRS delegations of the Contractor has right to request MCO beneficiaries' medical records from providers without first having to obtain patient's consent for the purposes of resolving quality of care issues, responding to or conducting clinical quality audits, and for responding to or conducting financial audits…"  Kansas Contract, Amendment Three.

KY

"IX.  SUBCONTRACTS...
B.  Requirements
  The Contractor may, with the approval of the Department, enter into Subcontracts for the performance of its administrative functions or the provision of various Covered Services to Members... No Subcontract shall in any way relieve the Contractor of any responsibility for the performance of its duties pursuant to the Contract…"  Kentucky Contract, pages 37-38.

ME

"X.  SUBCONTRACTS.
A.  PRIME CONTRACTOR LIABILITY
The Contractor is the ‘prime contractor’ hereunder, is the sole point of contact in all contractual matters, and shall be wholly responsible for performance of the entire Contract.  No subcontract into which the Contractor may enter shall in any way relieve, alter, or in any manner detract from the Contractor's responsibility or liability to perform its duties hereunder. All payments for services covered by this Contract shall be made only to the Contractor."  Maine Contract, page 56.

MD

"10.09.65.17...
(3)  When entering into a subcontract to transfer to the subcontracting provider the initial responsibility for providing specified health care services to the MCO's enrollees, an MCO retains a primary duty to the Department and to its enrollees to ensure that its subcontractor delivers the required services in a manner that is consistent with the requirements of COMAR 10.09.62-10.09.73."  Maryland COMAR 10.09.65.17.

MA

"SECTION 2.  CONTRACTOR RESPONSIBILITIES...
Section 2.2 Administration and Contract Management...
D.  Subcontractors
The Contractor shall: ...
3.  Remain fully responsible for meeting all of the terms and requirements of the Contract regardless of whether the Contractor subcontracts for performance of any Contract responsibility.  No subcontract will operate to relieve the Contractor of its legal responsibilities under the Contract…"  Massachusetts Contract, pages 16-18.

MABH

"17.  Subcontracting.  None of the services to be provided by the Contractor pursuant to this Contract shall be subcontracted or delegated in whole or in part to any other organization, association, individual, corporation, partnership or other such entity without the prior written approval of the Division.  No subcontract or delegation shall relieve or discharge the Contractor from any obligation or liability under this Contract except as specifically set forth in the instrument of approval..."  Massachusetts  MH/SAP Contract, page 5.

"B.  Delegation to Subcontractors
The Contractor shall: ...
5.  remain fully responsible for meeting all of the terms and requirements of the Contract.  No Provider Agreement, subcontract or other agreement with providers shall operate to relieve the Contractor of its legal responsibilities under the Contract."  Massachusetts MH/SAP Contract, Appendix A, pages 18-19.

MN

"Section 9.2. Subcontractors...
Section 9.2.6. Notwithstanding Section 9.2.1., the HEALTH PLAN may contract with providers of health care services to provide services to Enrollees of the HEALTH PLAN. Subcontracts with other providers of health care services shall not abrogate or alter the HEALTH PLAN's primary responsibility for performance under this Contract."  Minnesota Contract, page 84.

MO

"2.2.1 Health Plan Administration: … Similarly, the health plan may contract with a third party (subcontractor) to perform one or more of these functions.  The health plans will be responsible for assuring that the subcontractor complies with all standards and procedures as established by the State and demonstrate compliance to the state agency."  Missouri RFP, page 21.

"16.  The health plan is responsible for assuring their subcontractors are advised of these guidelines and that subcontractors adhere to them.  No subcontractor shall operate to relieve the Contractor of its obligations.  Health plans must have written procedures to assure subcontractor notification and monitor compliance to guidelines."  Missouri RFP, page 38.

"3.5  Subcontractors:
If approved by the State of Missouri in writing, the contractor may subcontract for those services described herein provided that any subcontracts include appropriate provisions and contractual obligations to ensure the successful fulfillment of all contractual obligations agreed to by the Contractor and the State of Missouri and to ensure that the State of Missouri is indemnified, saved, and held harmless from and against any and all claims of damage, loss, and cost (including attorney fees) of any kind related to a subcontract in those matters described in the contract between the State of Missouri and the Contractor.  The Contractor shall expressly understand and agree that contractor shall assume and be solely responsible for all legal and financial responsibilities related to the execution of a subcontract.

3.5.2… The Contractor shall agree and understand that utilization of a subcontractor to provide any of the equipment or services in the contract shall in no way relieve the contractor of the legal responsibility for providing the equipment or services as described and set forth herein.."  Missouri RFP, pages 101-102.

MT

"SECTION 10  ASSIGNMENT, TRANSFER AND SUBCONTRACTING...
B.  In the event the DEPARTMENT approves of any assignment, transfer, delegation or subcontract, the assignment, transfer, delegation or subcontract must meet any conditions stated in the DEPARTMENT'S written approval... Subcontracts shall not terminate legal liability of the CONTRACTOR under this contract."  Montana Contract, page 9.

NE

"8.9 Plan Responsibility: The plan shall solely be responsible for fulfilling all obligations imposed on it by this contract, with responsibility for all requirements as described. The plan shall be the sole point of contact regarding all contractual matters."  Nebraska Contract, page 18.

NEBH

"8.9 PHP Responsibility/Subcontracting: The PHP is solely responsible for fulfilling all obligations imposed on it pursuant to this contract.  The PHP shall be the sole point of contact regarding all contractual matters...

The PHP is not relieved of its responsibility for performing all obligations under this contract in the event a subcontractor is utilized."  Nebraska Behavioral Health Contract, page 18.

"8.40.10 Use of Intermediaries: The use of subcontractors by the PHP to perform one or more of the PHP’s claims handling functions shall not in any way mitigate responsibility of the PHP to comply with all of the terms of Section 8.41."  Nebraska Behavioral Health Contract, page 28.

NH

"Article II
Functions and Duties of Contractor
In consideration of the Agreement of the State contained in Article III, Contractor agrees: ...

2.17  SUBCONTRACTS-----To provide that all Subcontracts must be in writing. No Subcontract terminates the legal responsibility for assuring that all such Subcontracts fulfill the requirements of this Agreement..."  New Hampshire General Service Agreement, page 10.

NJ

"ARTICLE 21
CONTRACTS AND SUBCONTRACTS...
21.3  No subcontract will terminate the legal responsibility of the contractor to the Department to assure that all activities under this contract are carried out.  The contractor is not relieved of its contractual responsibilities to the Department by delegating responsibility to a subcontractor…" New Jersey Contract, page 118.

"Standards for Internal Quality Assurance Programs of HMOs, HIO's and PHPs Contracting with Medicaid...
STANDARD VIII:  DELEGATION OF QAP ACTIVITIES - The MCO remains accountable for all QAP functions, even if certain functions are delegated to other entities…"  New Jersey Contract, pages 203-209.

NM

"ARTICLE 20 - SUBCONTRACTS
20.1  The CONTRACTOR is solely responsible for fulfillment of the Agreement with HSD...
20.2  The CONTRACTOR shall remain solely responsible for performance by any subcontractor under such subcontract(s)...
20.4  Subcontracting Requirements...
  The CONTRACTOR remains legally responsible to HSD for all work performed by any subcontractor…" New Mexico Contract, page 90.

NY

"2.6  Assignment and Subcontracting...
b)...Contractor agrees that it shall remain legally responsible to LDSS for carrying out all activities under this Agreement and that no subcontract shall limit or terminate Contractor's responsibility…"  New York Contract, page 2-3.

22.  SUBCONTRACTS AND PROVIDER AGREEMENTS...
22.5  Required Components...
b) No subcontract, including any Provider Agreement shall limit or terminate the Contractor’s duties and obligations under this Agreement…"  New York Contract, pages 22-1-22-2.

NC

"SECTION 12 - SUBCONTRACTS
12.1  Requirements
The Plan may enter into subcontracts for the performance of its administrative functions or for the provision of various Covered Services to members…No subcontract shall in any way relieve the plan of any responsibility for the performance of its duties pursuant to this Contract…"  North Carolina Contract, pages 20-21.

ND

"9  ASSIGNMENT, TRANSFER, AND SUBCONTRACTING...
B… Subcontracts shall not terminate legal liability of the Contractor under this  contract."  North Dakota Contract, page 7.

"12  FINANCIAL RESPONSIBILITIES OF THE CONTRACTOR...
B.  The Contractor remains fully and solely responsible for all contract obligations…"  North Dakota Contract, page 9.

OH

"7.  Provider Networks…
(d)  Subcontracts…
The MCP remains accountable to ODHS for all responsibilities and duties incorporated under the provider agreement, including RFP and OAC rule provision."  Ohio RFP, pages 30-31.

"5101:3-26-05  Managed care plan:  provider panel and subcontracting requirements.
(A)  Obligations...
(4)  The execution of a subcontract does not terminate the MCP's legal responsibility to ODHS to assure that all of the MCP's activities and obligations are carried out in accordance with Chapter 5101:3-26 of the Administrative Code and the MCP provider agreement."  Ohio RFP, Appendix E, OAC 5101:3-26-05, page 1.

OK

"3.5.5  Subcontracts and Delegation of Duty...
The Health Plan shall be wholly responsible for performance of this entire agreement whether or not subcontractors are used. Any subcontract that Health Plan enters into with respect to performance under this agreement shall not relieve Health Plan in any way of responsibility for performance of its duties…"  Oklahoma RFP, page 81.

OR

"29.  SUBCONTRACTS/ASSIGNMENTS
A.  Subject to the provisions of this section, Contractor may subcontract any or all of the work to be performed under this Agreement. No subcontract shall terminate or limit Contractor's legal responsibility to OMAP for the timely and effective performance of its duties and responsibilities under this Agreement.

B.  Contractor shall not assign or transfer any of its interest in this Agreement or any claims arising therefrom or enter into any successor in interest agreement or process, without OMAP's prior written approval, and subject to such conditions and limitations as OMAP may, in its sole discretion, deem necessary…"  Oregon Contract, page 44.

ORMH

"O.  Delegation of Activities
Contractor is responsible for the quality of care and services provided under the terms and requirements of this Agreement.  Subject to the provisions of this section, Contractor may subcontract any or all of the work to be performed under this Agreement.  No subcontract shall terminate or limit Contractor's legal responsibilities to Division for the timely and effective performance of its duties and responsibilities under this Agreement." Oregon Mental Health Contract, page 37.

PA

"R.  CONTRACTS AND SUBCONTRACTS...
Contracts and Subcontracts entered into by the HMO shall not terminate the HMO's obligations under their contract with the Department…"  Pennsylvania RFP, pages 100-101.

RI

"3.05.05  Subcontracts And Delegation of Duty...
The prime Contractor shall be wholly responsible for performance of the entire contract whether or not subcontractors are used.  Any subcontract which Contractor enters into with respect to performance under this Agreement shall not relieve Contractor in any way of responsibility for performance of its duties.  Further, the State will consider Contractor to be the sole point of contact with regard to contractual matters, including payment of any and all charges resulting from the Agreement (see also Section 3.05.06, Assignment of the Contract)."  Rhode Island RFP, page 61.

SC

"5  SUBCONTRACTS...
The Contractor shall remain responsible for all contractual requirements including those performed by the subcontractor(s)."  South Carolina Contract, page 28.

TN

"2-10.  Administration and Management
   The CONTRACTOR shall be responsible for the administration and management of all aspects of this Agreement and the health plan covered thereunder.  This includes all subcontracts, provider agreements, employees, agents, and anyone acting for or on behalf of the CONTRACTOR...no subcontract, provider agreement or other delegation of responsibility terminates or reduces the legal responsibility of the CONTRACTOR to TENNCARE to assure that all activities under this Agreement are carried out…"  Tennessee Contract, page 46.

TX

"3.2  NON-PROVICER SUBCONTRACTS...
3.2.3  The form and substance of all subcontracts including subsequent amendments are subject to approval by TDH...  HMO REMAINS RESPONSIBLE FOR PERFORMING ALL DUTIES, RESPONSIBILITIES AND SERVICES UNDER THIS CONTRACT REGARDLESS OF WHETHER THE DUTY, RESPONSIBILITY OR SERVICE IS SUBCONTRACTED TO ANOTHER."  Texas Contract, pages 14-15.

"7.2  PROVIDER CONTRACTS...
7.2.4…  HMO REMAINS RESPONSIBLE FOR PERFORMING AND FOR ANY FAILURE TO PERFORM ALL DUTIES, RESPONSIBILITIES AND SERVICES UNDER THIS CONTRACT REGARDLESS OF WHETHER THE DUTY, RESPONSIBILITY OR SERVICE IS CONTRACTED TO ANOTHER FOR ACTUAL PERFORMANCE."  Texas Contract, pages 54-55.

"7.18  DELEGATED NETWORKS (IPAs, LIMITED PROVIDER NETWORKS AND ANHCs)…
7.18.7  HMO REMAINS RESPONSIBLE FOR PERFORMING ALL DUTIES, RESPONSIBILITIES AND SERVICES UNDER THIS CONTRACT REGARDLESS OF WHETHER THE DUTY, RESPONSIBILITY OR SERVICE IS CONTRACTED OR DELEGATED TO ANOTHER.  HMO MUST PROVIDE A COPY OF THE CONTRACT PROVISIONS THAT SET OUT HMO’S DUTIES, RESPONSIBILITIES, AND SERVICES TO ANY PROVIDER NETWORK OR GROUP WITH WHOM HMO CONTRACTS TO PROVIDE HEALTH CARE SERVICES ON A RISK SHARING OR CAPITATED BASIS OR TO PROVIDE HEALTH CARE SERVICES."  Texas Contract, pages 76, 78.

UT

"D.  Subcontracts...
  2.  Any Covered Service may be Subcontracted...
  No subcontract terminates the legal responsibility of the CONTRACTOR to the DEPARTMENT to assure that all activities under this Contract are carried out…"  Utah Contract, Attachment B, page 12.

UTMH

"C.  Subcontracts...
  2…No subcontract terminates the legal responsibility of the CONTRACTOR to the DEPARTMENT to assure that all activities under the Contract are carried out..."  Utah Mental Health Contract, page 12.

VA

"B.  CONTRACTOR MANAGEMENT AND ADMINSTRATION
The Contractor may enter into subcontracts for the provision or administration of any or all Medallion II and CMSIP covered services or enhanced services.  Subcontracting does not relieve the Contractor of its responsibilities to the Department or enrollees under this Contract."  Virginia Contract, page 17.

WA

"7.1  Contractor Remains Legally Responsible:  Subcontracts, as defined in section 1.16, may be used by the Contractor for the provision of any service under this agreement.  However, no subcontract shall terminate the Contractor's legal responsibility to DSHS for any work performed under this agreement (42 CFR 434.6 (c))."  Washington Contract, page 30.

WV

"3.25 Subcontracts
The Managed Care Plan may subcontract for any function covered by this contract, subject to the requirements of this contract…

Subcontracts shall not terminate legal liability of the Managed Care Plan under this contract… The Managed Care Plan is solely responsible for the fulfillment of this contract with the Department. The Managed Care Plan is required to assume prime contractor responsibility for all services offered and products to be delivered whether or not the Managed Care Plan is the provider of said services or product. The Department will consider the Managed Care Plan to be the sole point of contact with regard to all contractual matters."  West Virginia Contract, pages 24-25.

"6.4  SUBCONTRACTS
Contractor is solely responsible for all work performed under the Contract. Contractor is required to assume prime contractor responsibility for all services offered and products to be delivered. The Department will consider the Contractor to be the sole point of contact with regard to all contractual matters."  West Virginia RFA, page 63.

"IV-1  RESPONSIBILITY FOR ACTIVITIES DELEGATED TO OTHER ENTITIES
The MCO oversees and is accountable for any functions or responsibilities that are described in Domains I through III that are delegated to other entities..."  West Virginia Contract, Exhibit F, page 17.

WI

"II.  DELEGATIONS OF AUTHORITY
No delegations of authority are permitted under this Contract."  Wisconsin Contract, page 5.

"AA. SUBCONTRACTS - Assure that all subcontracts shall be in writing, shall comply with the provisions of Addendum I, and shall include any general requirements of this Contract that are appropriate to the service or activity identified in Addendum I, and to assure that all subcontracts shall not terminate legal liability of the HMO under this Contract. The HMO may subcontract for any function covered by this Contract, subject to the requirements of this Contract."  Wisconsin Contract, page 32.

"ADDENDUM I
SUBCONTRACTS AND MEMORANDA OF UNDERSTANDING...
The Department will review and approve or disapprove each subcontract before contract signing… The Department's subcontract review will assure that the HMO has inserted  the following standard language in subcontracts (except for specific provisions that are inapplicable in a specific HMO management subcontract): ...
(b)  No terms of this subcontract are valid which terminate legal liability of HMO in accordance with Article III. BB. Of the Medicaid/HMO Contract…"  Wisconsin Contract, page 72.