FDR Compliance Requirements and How To Meet Them

Downstream Entities

Requirements	How to Comply
Plan sponsors are responsible for the lawful and compliant administration of the Medicare and/or Medicaid benefits under their contracts with CMS, regardless of whether the plan sponsor has delegated some of that responsibility to FDRs, including their PBM. As a first tier entity, Navitus is monitored and audited by our 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). This monitoring includes an evaluation to confirm that the first tier entities are applying appropriate compliance program requirements to downstream entities with which the first tier entity contracts. (Medicare Prescription Drug Benefit Manual Ch. 9 §50.6.6	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 and/or Medicaid programs, your organization must distribute materials and information to your downstream entities and monitor and audit their performance to ensure their compliance with all applicable CMS requirements and the requirements in this site.

Requirements

How to Comply

Plan sponsors are responsible for the lawful and compliant administration of the Medicare and/or Medicaid benefits under their contracts with CMS, regardless of whether the plan sponsor has delegated some of that responsibility to FDRs, including their PBM. As a first tier entity, Navitus is monitored and audited by our 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). This monitoring includes an evaluation to confirm that the first tier entities are applying appropriate compliance program requirements to downstream entities with which the first tier entity contracts. (Medicare Prescription Drug Benefit Manual Ch. 9 §50.6.6

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 and/or Medicaid programs, your organization must distribute materials and information to your downstream entities and monitor and audit their performance to ensure their compliance with all applicable CMS requirements and the requirements in this site.