Medicare FDR Compliance

Gold Kidney has contracts with the Centers for Medicare and Medicaid Services (CMS) to provide services under Medicare Advantage and Part D programs. Gold Kidney relies on our contracted providers and other external contractors to help us meet the needs of our Medicare Members in accordance with CMS’ Medicare Advantage/Part D program requirements. These providers and contractors are considered by CMS to be First Tier, Downstream, and Related Entities (FDRs) because Gold Kidney has delegated administrative or healthcare functions relating to its contract with CMS.

Requirements for FDRs

Gold Kidney is committed to operating a health plan that meets the requirements of all applicable laws and regulations of the Medicare Advantage and Part D programs. As part of an effective compliance program, CMS requires Medicare Advantage plans to ensure any FDRs to which the provision of administrative or healthcare services are delegated are also in compliance with applicable laws and regulations. As our partner in serving our Medicare Members we want to thank you for ensuring your organization’s compliance with Medicare requirements. This page and associated links and documents describe some of the Medicare compliance program requirements applicable to you as an FDR.

Please review the content of this page and utilize the information and documentation provided to ensure compliance.

Annual Attestation

Gold Kidney has developed an annual attestation as part of our efforts to validate each contracted FDR has met CMS requirements. The attestation should be submitted within 90 days of contracting and annually thereafter. The attestation must be completed by an individual in your organization who has signatory authority to make the representations in the attestation.

The attestation addresses the compliance requirements covered in the Gold Kidney FDR Compliance Guide, including:

  • Completion of FWA and General Compliance training and maintaining record of the completion of training.
  • Distribution of Standards of Conduct and maintaining record of distribution
  • Federal exclusion list screening and maintaining record of timely checks against those lists
  • Record retention for 10 years.
  • The availability of a system to receive reports (reporting mechanism) of suspected noncompliance and/or FWA that is confidential, allows anonymity, and includes a policy of non-intimidation and non-retaliation.
  • Identification of use of offshore subcontractors
  • Monitoring and auditing downstream entities.
  • Annual Attestation/Offshore Subcontracting Attestation

Submit the Attestation to, upon Gold Kidney’s request.