Medicare FDR: First-Tier, Downstream, and Related Entities
In the Medicare industry, FDR stands for more than the initials of our 32nd president. It stands for First-Tier, Downstream, and Related Entities. As an agent, you are probably an FDR. We’ll break down what that means today so you can stay best informed.
The broadest of the three is a First-Tier Entity. It includes anyone who has a written agreement approved by CMS and provides administrative or health care services to Medicare-eligible individuals with MA (Medicare Advantage) or Part D (prescription drug coverage).
A Downstream Entity is anyone who has a written agreement approved by CMS with individuals involved with MA or Part D that is below the level of a First-Tier Entity. For example, this includes customer service representatives, claim administrators, application processors, and marketers.
Related Entities are related to an MA or Part D organization/sponsor. They perform management roles, provide service, lease property or sell materials worth more than $2,500.
Are you contracted and licensed to sell MA or Part D? If so, you’re probably an FDR. What does this mean for you? The title “FDR” brings special compliance guidelines with it. You may hear, “FDRs need to complete this training” or “FDRs are required to…”
FDRs must complete all training before their 90th day of work and must renew it every year. If you do not complete your training, CMS has the right to terminate your contract and stop you from selling. Training includes:
- CMS FWA (Fraud, Waste, and Abuse) training
- General CMS compliance training
- Code of conduct policy distribution
- Exclusion list screenings (checks your history of working in health care)
- Any other federal and state certifications
It’s in your best interest to hold on to any verifications and evidence of your certifications and training.