DOWNSTREAM ENTITIES. Plan sponsors are responsible for the lawful and compliant administration of the Medicare Part D benefits under their contracts with CMS, regardless of whether the plan sponsor has delegated some of that responsibility to FDRs, including their PBM.
https://www.navitus.com/getdoc/0eb04f0f-fcd6-4b48-b664-d9112d125d8b/FDR-Requirements-(6).aspx
General Compliance Training. As a First Tier, downstream or related entity who provides administrative or healthcare. services to Medicare beneficiaries on behalf of HPP, you must at a minimum, provide. any new employee, temporary employee, volunteer, consultant, governing body. member or delegated vendors Fraud, Waste, and Abuse training and General.
https://medicare.healthpartnersplans.com/media/100141140/508-FDR-Guide.pdf
We’re committed to practicing business in an ethical manner. Our Medicare compliance program helps to: • Reduce or eliminate fraud, waste and abuse (FWA) • Make sure we comply with applicable laws, rules and. regulations. • Reinforce our commitment to compliance. We use external entities to bring our members.
https://www.aetnaeducation.com/ihtml/application/upload/9472.pdf
As a First Tier, downstream or related entity that provides administrative or healthcare. services to Medicare beneficiaries, your organization is required to review the DHHS. Office of Inspector General (OIG) List of Excluded Individuals and Entities (LEIE list) and.
https://medicare.healthpartnersplans.com/media/100141140/508-FDR-Guide.pdf
If your organization subcontracts with other entities (external vendors to your organization and downstream entities to Navitus) to perform any of the services contractually delegated to your organization by Navitus for Medicare Part D programs, your organization must distribute materials and information to your downstream entities and monitor and ...
https://www.navitus.com/getdoc/0eb04f0f-fcd6-4b48-b664-d9112d125d8b/FDR-Requirements-(6).aspx
As a first tier entity, Navitus is monitored and audited by our Medicare Part D plan sponsors to ensure we are in compliance with all applicable laws and regulations, and to ensure that we are monitoring the compliance of the entities with which we contract (“downstream” entities).
https://www.navitus.com/getdoc/0eb04f0f-fcd6-4b48-b664-d9112d125d8b/FDR-Requirements-(6).aspx
Each day we must remember our commitment to do the right. thing for the right reason and keep the people we serve at the center of everything we do. When we act with integrity, we are living The Aetna Way. Our Medicare Compliance Program helps us serve our members ethically.
http://coventryhealthcare.com/web/groups/public/@cvty_corporate_chc/documents/document/c118172.pdf
Although we contract with FDRs to provide administrative and/or healthcare services for our. Medicare Plans, in the end, we’re responsible for fulfilling the terms and conditions of our. contract with CMS and meeting applicable Medicare program requirements. Compliance program requirements.
http://coventryhealthcare.com/web/groups/public/@cvty_corporate_chc/documents/document/c118172.pdf
Downstream Entity is any party that enters into a written. arrangement, acceptable to CMS, with persons or entities. involved with the MA benefit or Part D benefit, below the. level of the arrangement between an MA organization or. applicant or a Part D plan sponsor or applicant and a First Tier.
https://www.aetnaeducation.com/ihtml/application/upload/9472.pdf
Introduction – Aetna’s Medicare Compliance Program. Aetna’s reputation as an industry leader depends on our ability to deliver on our promises. For. more than 160 years, we have been guided by the highest standards of integrity.
http://coventryhealthcare.com/web/groups/public/@cvty_corporate_chc/documents/document/c118172.pdf
what are we responsible for with a downstream entity
With a downstream entity, we are responsible for the lawful and compliant administration of the Medicare Part D benefits under their contracts with the centers for medicare & medicaid services, regardless of whether the plan sponsor has delegated some of that responsibility to downstream and related entities, including their pharmacy benefit managers.