Univeristy of Arizona Health Network
2016 Compliance Program
Requirements for
First Tier, Downstream and Related Entity Annual Attestation and Disclosure Statement
Your Organization is receiving this “Annual Attestation and Disclosure Statement” because your Organization is contracted with The University of Arizona Health Plans (UAHP) as a First Tier, Downstream or Related Entity (FDR) (CMS) and/or an Administrative Service Subcontractor or Provider (AHCCCS) for UAHP’s Medicare and/or Medicaid products. As a UAHP Medicare and/or Medicaid contractor, the Organization is subject to federal and state laws related to the Medicare and Medicaid programs as well as CMS and state Medicaid program (AHCCCS) rules, regulations and sub-regulatory guidance. This includes ensuring the Organization’s employees and downstream contractors abide by said federal and state laws, regulations, and sub-regulatory guidance.
Please review the following sections:
Section 1: Medicare and Medicaid Participation Compliance Program Requirements
Section 2: Attestations
Section 3: Organization Information and Signature
CMS defines subcontractors as:
First Tier Entity is any party that enters into a written arrangement, acceptable to CMS, with a Medicare Advantage Organization or Part D plan sponsor or applicant to provide administrative services or healthcare services to a Medicare eligible individual under the Medicare Advantage program or Part D program.
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.
Related Entity means any entity that is related to a Medicare Advantage Organization or Part D sponsor by common ownership or control and:
  1. Performs some of the Medicare Advantage Organization or Part D plan Sponsor’s management functions under contract or delegation;
  2. Furnishes services to Medicare enrollees under an oral or written agreement; or
  3. Leases real property or sells materials to the Medicare Advantage Organization or Part D plan Sponsor at a cost of more than $2,500 during a contract period.
The State Medicaid Program (AHCCCS) defines subcontractors as:
Administrative Service Subcontractors
A subcontractor that UAHP delegates any of the requirements of the AHCCCS Acute Care Contract to including but not limited to the following:
  1. Claims processing, including pharmacy claims
  2. Credentialing, including those for only primary source verification (i.e. Credential Verification Organization).
  3. Management Service Agreements
  4. Service Level Agreements with any Division or Subsidiary of a corporate parent owner
Any person of entity that contracts with the AHCCCS or UAHP for the provision of covered services to members according to the provisions A.R.S. §36-2901 or any subcontractor of a provider delivering services pursuant to A.R.S. §36-2901.
*For consistency throughout this document, UAHP will refer collectively to its subcontractors as FDRs.
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