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FDR Compliance Requirements and How to Meet Them

Navitus is committed to operating a PBM that meets the requirements of all applicable laws and regulations of these programs. As part of an effective compliance program, the Centers for Medicare and Medicaid Services (CMS) requires plan sponsors and their PBMs to ensure that any vendors to which the provision of administrative or healthcare services are delegated are also in compliance with applicable laws and regulations. This includes but is not limited to the following plan types:

  • Medicare Advantage (MA)
  • Prescription Drug (MAPD)
  • Prescription Drug Plans (PDP)
  • Medicare-Medicaid Plans (MMP)
  • Special Needs Plans (SNP)
  • Program of All-inclusive Care for the Elderly (PACE)
  • Some State Medicaid plans

The key compliance requirements for Vendor/FDRs and recommendations for meeting those requirements are outlined below. Navitus provides FWA Attestations for your organization to validate compliance with these requirements. Pharmacies may access the FWA Attestation through the Navitus Pharmacy Portal or through NCPDP.

The recommendations provided in this Section for “How to Comply” below are suggestions and should not replace legal advice or analysis by your organization in meeting your compliance obligations. Additionally, these recommendations are not intended to encompass all of your compliance obligations as these relate to the function(s) your organization may be performing under the Medicare or Medicaid program only.