Medicare FDR Compliance
Paramount has contracts with the Centers for Medicare and Medicaid Services (CMS) to provide services under Medicare Advantage and Part D programs. Paramount relies on our contracted providers and other external contractors to help us meet the needs of our Medicare Members in accordance with CMS’ Medicare Advantage/Part D program requirements. These providers and contractors are considered by CMS to be First Tier, Downstream, and Related Entities (FDRs) because Paramount has delegated administrative or healthcare functions relating to its contract with CMS.
Requirements for FDRs
Paramount is committed to operating a health plan that meets the requirements of all applicable laws and regulations of the Medicare Advantage and Part D programs. As part of an effective compliance program, CMS requires Medicare Advantage plans to ensure any FDRs to which the provision of administrative or healthcare services are delegated are also in compliance with applicable laws and regulations.
As our partner in serving our Medicare Members we want to thank you for ensuring your organization’s compliance with Medicare requirements. This page and associated links and documents describe some of the Medicare compliance program requirements applicable to you as an FDR.
Please review the content of this page and utilize the information and documentation provided to ensure compliance.
In addition, to support FDRs with their compliance efforts, Paramount has developed an FDR Compliance Guide. Please review this guide to confirm you have internal processes in place to support your compliance with all of the Medicare Compliance Program requirements.
Paramount has developed an annual attestation as part of our efforts to validate each contracted FDR has met CMS requirements. The attestation should be submitted within 90 days of contracting and annually thereafter. The attestation must be completed by an individual in your organization who has signatory authority to make the representations in the attestation.
The attestation addresses the compliance requirements covered in the Paramount FDR Compliance Guide, including:
- Completion of FWA and General Compliance training and maintaining record of the completion of training.
- Distribution of Standards of Conduct and maintaining record of distribution.
- Federal exclusion list screening and maintaining record of timely checks against those lists.
- Record retention for 10 years.
- The availability of a system to receive reports (reporting mechanism) of suspected noncompliance and/or FWA that is confidential, allows anonymity, and includes a policy of non-intimidation and non-retaliation.
- Identification of use of offshore subcontractors.
- Monitoring and auditing downstream entities.
- Annual Attestation/Offshore Subcontracting Attestation
- Submit the Attestation to PhcDelegateOversight@promedica.org, upon Paramount’s request.
Paramount’s Compliance Program
Paramount operates within one of the nation’s most heavily regulated industries. To promote the highest legal and ethical standards within Paramount to ensure we meet or exceed the federal and state requirements for insurance carriers, Paramount has implemented a comprehensive, integrated Compliance Program and Fraud, Waste, and Abuse (FWA) Program. CMS expects Paramount to share our standards of conduct and compliance principles with our FDRs. In addition, we must ensure our FDRs adopt and follow either Paramount’s or their own standards and principles that reflect a commitment to detecting, preventing and correcting noncompliance with Medicare requirements, including those regarding fraud, waste, and abuse. This material must be shared with the FDR (by Paramount) and FDR’s employees (by FDR) within 90 days of hire/contract effective date and annually thereafter.
- ProMedica Compliance Plan
- ProMedica Compliance Plan Supplement - Paramount
- Paramount Delegation Oversight Policy
- Corporate Compliance with Vendors
- False Claims Education Policy
- Standards of Conduct
- Disciplinary Standards
- FDR agrees to comply with Paramount’s Standards of Conduct and policies and procedures, or to adopt and comply with its own code of conduct, disciplinary standards and policies and procedures that reflect a commitment to detecting, preventing and correcting non-compliance with Medicare requirements in the delivery of Medicare services, including detecting, preventing and correcting fraud, waste and abuse.
- FDR is required to publish disciplinary standards which include its expectation that employees ask Medicare compliance questions and report potential and actual instances of noncompliance with Medicare requirements. Disciplinary standards must also state that any violation of these standards will result in appropriate disciplinary action, up to and including termination of employment. They also must include a non-retaliation policy for good-faith reporting.
CMS Online Resources
CMS provides a wealth of Medicare related educational tools and other resources at www.cms.gov. Below are links to the tools/resources applicable to FDR requirements referenced in the Paramount FDR Compliance Guide:
- CMS Medicare Learning Network
- Office of Inspector General, Exclusion Database (OIG LEIE)
- General Services Administration, System for Award Management (GSA SAM)
- Medicare Managed Care Manual (see Chapters 11 and 21)
Reporting Compliance Issues and Fraud, Waste and Abuse
Reporting is key in the prevention, detection, and correction of program noncompliance and FWA. Paramount protects any individual or organization who reports a legitimate concern in good faith from retaliation and intimidation. FDRs are expected to do so as well.
FDRs who fail to report known and/or possible violations or suspected FWA could result in disciplinary action up to and including termination of your contract with Paramount. To the extent possible, reports are kept confidential. Anonymous reporting is available through the Compliance Hotline.
Reports can be made to Paramount by doing any of the following:
- Call the Compliance Hotline at 1-800-807-2693
- Email: Paramount.Regulatory@ProMedica.org
- Write to Paramount’s Compliance Director at:
Attn: Sue Harris, Compliance Director
1901 Indian Wood Circle
Maumee, OH 43537
The Delegation Oversight Team of Paramount is responsible to ensure FDRs continue to meet the CMS contractual obligations on an ongoing basis. The Team is happy to answer all your questions and concerns regarding your FDR status and/or compliance requirements. Contact us at: PhcDelegateOversight@promedica.org.