FDR Compliance Requirements and How to Meet Them
Navitus is committed to operating a PBM 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, the Centers for Medicare and Medicaid Services (CMS) requires plan sponsors and their PBMs to ensure that any FDRs to which the provision of administrative or healthcare services are delegated are also in compliance with applicable laws and regulations.
The key compliance requirements for FDRs and recommendations for meeting those requirements are outlined below. Navitus provides a Non-Pharmacy FDR Annual Compliance and FWA Attestation and Participating Pharmacy Annual Compliance and FWA Attestation for your organization to validate compliance with these requirements.
The recommendations provided in this Section for “How to Comply” below are suggestions and should not replace analysis by your organization in meeting your compliance obligations. Additionally, these recommendations are not intended to encompass all of your compliance obligations as these relate to the function(s) your organization may be performing under the Medicare Part D program only.