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CMS compliance attestation

First Tier, Downstream or Related Entity (FDR)

In accordance with the Centers for Medicare and Medicaid Services (CMS) regulations, Geisinger Health Plan requires your company to fulfill and attest to meeting requirements in the following areas:

Geisinger Health Plan Code of Conduct

  • Communicates GHP's compliance expectations
  • Your own organization's standards of conduct may be used if it meets all CMS requirements
  • Code of Conduct must be distributed to each of your employees within 90 days of employment and annually thereafter

OIG/GSA exclusion list checks

  • Performed for all employees, pharmacies, vendors, board members or related individuals and entities
  • Performed prior to hire or engagement start date and monthly thereafter

Search the exclusions database

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All fields are required unless marked optional

I attest that in accordance with CMS requirements I have received and reviewed GHP's Code of Conduct which includes a mechanism to report suspected compliance and fraud concerns; that the GHP Code of Conduct or its equivalent has been distributed to all employees, pharmacies, vendors, board members or related individuals and entities within the required timeframes; and

I attest that in accordance with CMS requirements, company meets all oversight requirements for all downstream entities which company contracts for services. A downstream entity is 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 GHP and a first tier contracted entity. These written arrangements with downstream entities continue down to the level of the ultimate provider of both health and administrative services; and

I attest that all of our employees, pharmacies, vendors, board members or related individuals and entities have been screened against the OIG List of Excluded Individuals/Entities prior to hire and monthly thereafter, and that all of those entities and individuals identified as being excluded have been or will be immediately reported to GHP's Compliance Officer and have been or will be immediately removed from any work, either directly or indirectly, related to Federal health care programs, including Medicare Advantage Prescription Drug plans and Medicaid.

I attest that all of our employees have been made aware a reporting mechanism for compliance and fraud related concerns and a nonretaliation policy for good faith reporting.