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The Centers for Medicare and Medicaid Services (CMS), in its regulatory guidance, refers to our contracted partners as First-Tier, Downstream, and related Entitles, or FDRs. (see 42 C.F.R. §423.501).

First Tier Entity:  any party that enters into a written arrangement, acceptable to CMS, with an 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

  1. Performs some of the MAO or Part D plan sponsor’s management functions under contract or delegation;
  2. Furnishes services to Medicare enrollees under an oral or written agreement; or
  3. 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.


Navitus is committed to meeting the requirements of all applicable laws and regulations of the Medicare Part D programs.  Our commitment to this is embodied in our standards of conduct titled the “Navitus Code of Conduct”. The Code of Conduct is something each Navitus employee commits to uphold in his/her job and these standards are regularly reinforced with employees and Navitus-contracted participating pharmacies and vendors.

According to CMS rules and Navitus’ contractual terms with our Medicare D plan sponsors, Navitus must implement a compliance program that is effective in preventing, detecting, and correcting Medicare Part D program noncompliance as well as program Fraud, Waste, and Abuse (FWA). The compliance program is evaluated regularly to ensure adherence to CMS’ seven elements of an effective compliance program.