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The Centers for Medicare and Medicaid Services (CMS), in its regulatory guidance, refers to a Medicare and/or Medicaid Plan Sponsor’s contracted partners as First-Tier, Downstream, and related Entitles, or FDRs. (see 42 C.F.R. §423.501).

First Tier Entity (F) - any party that enters into a written arrangement, acceptable to CMS, with a Medicare and/or Medicaid plan sponsor or applicant to provide administrative services or health care services to a Medicare and/or Medicaid-eligible individual under these programs. Navitus Health Solutions (Navitus) is a First Tier Entity.

Downstream Entity (D) - any party that enters into a written agreement, acceptable to CMS, with persons or entities involved with the Medicare and/or Medicaid, below the level of first tier entity. These arrangements, often subcontractors, continue down to the level of the ultimate provider of both health and administrative services. This includes pharmacies participating in Navitus pharmacy network and vendors providing services on behalf of Navitus that have been delegated by Plan Sponsors.

Related Entity (R):  any entity that is related to an plan sponsor by common ownership or control and

  1. Performs some of the plan sponsor’s management functions under contract or delegation;
  2. Furnishes services to Medicare enrollees under an oral or written agreement; or
  3. Leases real property or sells materials to the Medicare plan sponsor at a cost of more than $2,500 during a contract period.


Navitus is committed to meeting the requirements of all applicable laws and regulations of the Medicare Part C and D and Medicaid programs.  Our commitment to this is embodied in our standards of conduct in which each Navitus employee commits to uphold in his/her job and these standards are regularly reinforced with employees and Navitus-contracted participating pharmacies and Vendors/FDRs.

According to CMS rules and Navitus’ contractual terms with our Medicare  and Medicaid plan sponsors, Navitus must implement a compliance program that is effective in preventing, detecting, and correcting program noncompliance as well as program Fraud, Waste, and Abuse (FWA). The compliance program is evaluated regularly to ensure adherence to CMS’ seven elements of an effective compliance program.