What is an FDR?
First Tier: any party that enters into a written arrangement, acceptable to CMS, with a Medicare Advantage Organization (MAO), or Part D plan sponsor or applicant to provide administrative services or health care services to a Medicare-eligible individual under the MA program or Part D program.
Downstream Entity: any party that enters into a written arrangement, acceptable to CMS, with persons or entities involved with the MA benefit or Part D benefit, below the level of the arrangement between an MAO or applicant or a Part D plan sponsor or applicant and a first-tier entity. These written arrangements continue down all levels through to the ultimate provider of both health and administrative services.
Related Entity: any entity that is related to an MAO or Part D sponsor by common ownership or control and
- Performs some of the MAO or Part D plan sponsor’s management functions under contract or delegation;
- Furnishes services to Medicare enrollees under an oral or written agreement; or
- Leases real property or sells materials to the MAO or Part D plan sponsor at a cost of more than $2,500 during a contract period.
How do pharmacies fit in?
A Pharmacy that provides services to Medicare health plan enrollees as required by CMS is considered a “downstream entity” and must comply with CMS requirements. For specific information regarding those requirements see our Compliance Guide.