Regence contracts with the Centers for Medicare & Medicaid Services (CMS) to provide Medicare Advantage and Prescription Drug Plans that provide health care and prescription drug benefits to Medicare beneficiaries. As a part of these contracts, CMS requires us to oversee our first tier, downstream and related entities (FDRs) that assist us in providing services for our Medicare beneficiaries. Examples of FDRs include providers, agents and brokers, pharmacies, claims processors, healthcare facilities and other vendors who help us deliver benefits.
As an FDR in Regence Medicare Advantage and Part D plans, you are an important partner in the continued success of our Medicare program. As such, Medicare requires FDRs to participate in our Medicare compliance program.
Regence is committed to providing you with the tools needed to ensure you meet the obligations under our Medicare compliance program. We provide our standards of conduct, resources for reporting concerns or issues and more, on a public website for you.
Examples of expectations include reading the Code of Business Conduct, completing Medicare Fraud, Waste & Abuse training and filling out the Conflict of Interest statement and keeping it on file. See your contract and the link below for additional requirements. Please contact your Regence representative with any questions.
CMS requires FDR employees to complete its Medicare fraud, waste, and abuse training within 90 days of hire and annually thereafter.
Required FWA training is developed and provided by CMS and is available through the CMS Medicare Learning Network (MLN) at http://www.cms.gov/MLNProducts. Once done, you must complete the attestation form on the last page of the training.
Note: FDRs must use only CMS or Regence FWA training to be compliant with this requirement.
Completed attestations or training logs must be made available for review, upon request.
Thank you for your cooperation. If you have any questions about whether your organization is required to complete FWA training, please contact your Regence representative. If you need assistance or have comments, please email the webmaster.
CMS expects Regence to share our standards of conduct with our FDRs and either ensure that these entities adhere to our standards or ensure that these entities adopt and follow their own standards of conduct. These standards reflect a commitment to detecting, preventing and correcting noncompliance with Medicare requirements, including detecting, preventing and correcting fraud, waste and abuse.
The following links are to Regence's Code of Business Conduct and Code of Business Conduct Guide.
CMS expects Regence to regularly audit conflict of interest certifications from our FDRs. Regence requires annual completion of these certifications because it ensures that each FDR has effectively screened managers, officers, and directors responsible for the administration or delivery of Medicare Advantage and Part D benefits. An annually or upon hire signed conflict of interest statement attests that the manager, officer, or director is free from any conflict of interest in administering or delivering these benefits.
Completed COI disclosure forms must be made available for review, upon request.
All FDRs must review the exclusion databases listed below prior to hire and monthly thereafter for current employees, officers & directors, board members, subcontractors, consultants and vendors, as applicable. You must notify Regence immediately if an exclusion is identified. Excluded persons or entities are prohibited from receiving payment.
Exclusion logs that include employee name, date each database was checked and whether or not an exclusion was found must be made available for review, upon request.
Review this FDR FAQ to determine if your Medicare Compliance program and documentation meet current guidelines.
Regence is committed to ethical business practices; complying with all Medicare requirements; and detecting, preventing and correcting fraud, waste and abuse. If you have concerns about ethics, compliance, or fraud, please consult the following resources.
Anonymous Medicare Compliance Hotline: (877) 878-2273
Fraud and Abuse
Fraud Related to Medicare Part D: (877) 479-8477
Fraud Related to Medicare Part C: (800) 548-4850
Ethics and Compliance