This attestation confirms your organization’s receipt of the Provider Partners Code of Ethical Business Conduct and Medicare Compliance Guide for First Tier, Downstream, and Related Entities (FDRs) and Key Compliance Policies Document. It also confirms your commitment to comply with the Centers for Medicare & Medicaid Services (CMS) requirements and Provider Partners Health Plans requirements. These requirements apply to services your organization, as a First-Tier Entity or Related Entity, provide for Provider Partners and, also applies to any of the related or downstream entities you use for Provider Partners contracted services.
 CMS’s guidance for Medicare Advantage organizations and Part D sponsors are published in both, Pub. 100-18, Medicare Prescription Drug Benefit Manual, Chapter 9 and in Pub.100-16, Medicare Managed Care Manual, Chapter 21, and are identical in each. Other applicable CMS regulatory/sub-regulatory guidance includes but is not limited to: CY2019 Final Rule CMS-4182-F published April 16, 2018; 42C.F.R.§§422 & 423; and associated CMS Manuals and HPMS memos.
 First-tier entity is any party that enters into a written arrangement, acceptable to CMS, with a Medicare Advantage or Part D plan sponsor, or applicant to provide administrative services or health care services to Medicare eligible individual under the Medicare Advantage program or Part D program (See, 42 C.F.R. §§422.500 & 423.501)
 Related Entity means any entity that is related to a MA Organization (MAO) or Part D Sponsor by common ownership or control and (1) performs some of the MAO or Part D Sponsor’s management functions under contract or delegation. (2) 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 more than $2,500 during a contract period.
 Downstream Entity is any party that enters into a written arrangement, acceptable to CMS, with persons or entities involved with the Medicare Advantage benefit or Part D benefit, below the level of the arrangement between a Medicare Advantage Organization or applicant or a Part D plan sponsor or applicant and a first-tier entity. These written arrangements continue down to the level of the ultimate provider of both health and administrative services. (See, 42 C.F.R. §§ 422.500 & 423.501)