FDR Compliance Requirements and How To Meet Them

OIG And GSA Exclusion Screening

Requirements	How to Comply
As a first tier entity, our Plan Sponsors require that Navitus and their downstream entities review the DHHS OIG List of Excluded Individuals and Entities (LEIE list) and the GSA System for Award Management exclusion list (SAM) prior to the hiring or contracting of any new employee, temporary employee, volunteer, consultant, governing body member, or Vendor/FDR, and monthly thereafter. This is to ensure that none of these persons or entities are excluded or become excluded from participation in federal programs. Monthly screening is required to prevent inappropriate payment to pharmacies, vendors, and other entities that have been added to exclusions lists since the prior month. (Medicare Prescription Drug Benefit Manual Ch. 9 §50.6.8)	Review the Department of Health and Human Services (DHHS) Office of Inspector General (OIG) List of Excluded Individuals and Entities (LEIE) for employees and any vendors or FDRs at the time of hiring or contracting and monthly thereafter. The LEIE is available at: https://oig.hhs.gov/exclusions/exclusions_list.asp. Review the General Service Administration (GSA) System for Award Management (SAM) for employees and any vendors or FDRs at the time of hiring or contracting and monthly thereafter. SAM is available at: https://www.sam.gov. Where a state Medicaid program requires screening against a state Medicaid exclusion, preclusion or other debarment list, employees and any vendors or FDRs must be screened at the time of hiring or contracting and monthly thereafter. Be prepared to produce documentation that your employees and any vendors or FDRs with whom you contract have been checked timely against the exclusion lists.

Requirements

How to Comply

As a first tier entity, our Plan Sponsors require that Navitus and their downstream entities review the DHHS OIG List of Excluded Individuals and Entities (LEIE list) and the GSA System for Award Management exclusion list (SAM) prior to the hiring or contracting of any new employee, temporary employee, volunteer, consultant, governing body member, or Vendor/FDR, and monthly thereafter. This is to ensure that none of these persons or entities are excluded or become excluded from participation in federal programs. Monthly screening is required to prevent inappropriate payment to pharmacies, vendors, and other entities that have been added to exclusions lists since the prior month. (Medicare Prescription Drug Benefit Manual Ch. 9 §50.6.8)

Review the Department of Health and Human Services (DHHS) Office of Inspector General (OIG) List of Excluded Individuals and Entities (LEIE) for employees and any vendors or FDRs at the time of hiring or contracting and monthly thereafter. The LEIE is available at: https://oig.hhs.gov/exclusions/exclusions_list.asp.
Review the General Service Administration (GSA) System for Award Management (SAM) for employees and any vendors or FDRs at the time of hiring or contracting and monthly thereafter. SAM is available at: https://www.sam.gov.
Where a state Medicaid program requires screening against a state Medicaid exclusion, preclusion or other debarment list, employees and any vendors or FDRs must be screened at the time of hiring or contracting and monthly thereafter.
Be prepared to produce documentation that your employees and any vendors or FDRs with whom you contract have been checked timely against the exclusion lists.