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Requirements How to Comply

In order to communicate compliance expectations for FDRs, Standards of Conduct and policies and procedures must be distributed to FDRs’ employees.  Distribution must occur within 90 days of hire, when there are updates to the policies, and annually thereafter.

Navitus makes Standards of Conduct and policies and procedures available to its FDRs. Alternatively, the FDR has comparable policies and procedures and Standards of Conduct of its own that it may use.(Medicare Prescription Drug Benefit Manual Ch. 9 §50.1.3)

You can either distribute your organization’s own Standards of Conduct and compliance policies and procedures to your employees or you may distribute the Navitus materials.

Navitus makes its Vendor Code of Conduct available to FDRs. Applicable Navitus Compliance Policies and Procedures are also available.