Medicare FDR Information
Thank you for your partnership with Health Partners Plans (HPP) to help us provide exceptional service to our Medicare members.
The Centers for Medicare & Medicaid Services (CMS) refers to our contracted partners as First-Tier, Downstream, and Related entities, or FDRs. HPP is required to effectively manage and oversee its FDRs that assist us in providing administrative and/or healthcare services for our Medicare members. Examples of FDRs include field marketing organizations, agents, providers, pharmacies, pharmacy benefit managers, claim administration vendors, fulfillment vendors and other vendors who help us deliver benefits.
HPP maintains the ultimate responsibility for fulfilling the terms and conditions of its contract with CMS. CMS may hold HPP accountable for the failure of its FDRs to comply with Medicare program requirements.
An authorized representative from your organization is required to submit the HPP FDR Compliance Program Attestation on an annual basis. In doing so, you attest to your organization’s compliance with these Medicare Compliance Program requirements.
To help ensure that we meet Medicare program requirements, we provide you with the following:
- Descriptions of First Tier, Downstream, and Related Entity
- Code of Conduct/Compliance Policy/Conflict of Interest
- Office of Inspector (OIG)/System for Award Management (SAM) Exclusion Screening
- Reporting FWA and Compliance Concerns
- Offshore Subcontracting Reporting
- Ongoing Monitoring and Auditing
- Downstream Entities
- Important Information
Code of Conduct & Reporting
Reporting non-compliance and FWA within your organization:
- Your manager knows you and your job and can often apply his or her business experience to help you make the right decision
- Contact your organization's compliance department or general counsel
- Use other reporting methods made available to you by your organization
Various mechanisms are in place for reporting concerns directly to HPP, such as:
- File a report through www.healthpartnersplans.com/report-compliance-issue. Reports filed through this webpage will be handled by a third party vendor on behalf of HPP. An option for anonymous reporting is provided on the webpage.
- Call the Compliance Hotline - 1-866-477-4848. The hotline is answered by a third-party vendor on behalf of HPP, and is available 24/7. Although you may identify yourself within your report, you will also be afforded the right to remain anonymous. At the end of your report, you will be provided with an ID number that you may also use to call back and receive updates on any investigations.
- Email compliance concerns to firstname.lastname@example.org
- Email suspected or actual fraud, waste and abuse concerns to SIUtips@hpplans.com
- Call or email Shawn Adams, Compliance Officer: 267-385-3854 or SAdams@hpplans.com
- Call or email Bryan Graves, Virtual Chief Information Security Officer: 615-473-1440 or email@example.com. If sending an email, please copy Daniel Reither at DReither@hpplans.com.
- Call or email Johnna Baker, General Counsel: 215‐991‐4051 or JBaker@hpplans.com
- HPP Code of Business Conduct (COBC)
- HPP's Compliance Program
- Reporting Concerns of Actual or Suspected Non-Compliance
- Reporting Concerns of Actual or Suspected Fraud, Waste, or Abuse
Network Providers: Please complete the Provider Compliance Attestation Form.
Delegated Vendors: As a continuing or newly contracted vendor delegated a function to perform on behalf of HPP, please complete the appropriate Delegated Vendor Compliance Attestation Form.
- Provider Compliance Attestation Form
- Delegated Vendor Compliance Attestation Form
- Delegated Vendor Compliance Attestation Form (for newly contracted vendors)
- Offshore Subcontractor Attestation Form
- Downstream Entity Online Form
If you have questions regarding the FDR information provided on this webpage, please feel free to contact your appropriate Health Partners Plans representative or email MedicareFDR@hpplans.com.