Affinity requires our providers to conduct business directly or indirectly related to Affinity in a compliant, ethical, and legal manner. In accordance with Centers for Medicare & Medicaid Services (CMS) requirements, Medicare Advantage Organizations (MAO), Medicare-Medicaid Plans (MMP) and Medicare Part D (PDP) sponsors are obligated to require completion of annual fraud, waste, and abuse (FWA) and general compliance training by their first-tier, related, and down-stream entities (FDR). In addition, FDRs are required to monitor federal exclusions lists on a monthly basis as well as annually distribute code or standards of conduct information.
Affinity uses the Centers for Medicare & Medicaid Services (CMS) standardized Medicare Parts C & D Fraud, Waste and Abuse (FWA) and General Compliance training module. This training module satisfies the regulatory requirement for effective training and education (42 CFR 422.503 and 42 CFR 423.504) and is referenced below along with other compliance-related documents for your convenience.
In order to comply with CMS requirements, Affinity asks that each of our contracted network providers review the CMS training materials along with Affinity's Code of Ethics (the standards of conduct for Affinity employees, board members, providers, vendors, and business partners) and attest that, to the extent required, will operate in a manner consistent with this document and training materials.
This attestation is required to be completed by December 31 of each calendar year. Each contracted network provider must complete Affinity's compliance attestation indicating that they have received and completed FWA and general compliance training materials and are applying the additional compliance requirements concerning Medicare Advantage, Medicare-Medicaid Plans (MMP) and Medicare Part D business.
Note that completion of the Affinity attestation is still required if your organization qualifies for the waiver based on meeting the fraud, waste, and abuse certification requirements through enrollment into the Medicare program or accreditation as a Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) provider and are deemed to have met the training and education requirements for fraud, waste, and abuse per 42 CFR 423.504. To indicate the deemed status, please check the appropriate section of the attestation.
Provider Compliance Resources
Training: Medicare Parts C & D Fraud, Waste, and Abuse (FWA) and General Compliance training module
Standards of Conduct: Affinity Code of Ethics
Provider Attestation Form: Affinity's Provider Compliance Attestation
Special Needs Plan Model of Care: Information about Affinity’s Model of Care (MOC).
Definitions of First Tier, Downstream, and Related Entity
Affinity's business partners considered an FDR include hospitals, providers, ancillaries, and a portion of our vendors. Below is a list of administrative or health care services examples that qualify a vendor as an FDR:
First Tier Entity
Defined as any party that enters into a written arrangement, acceptable to CMS, with a Medicare Advantage Organizations (MAO) or Part D plan sponsor or applicant to provide administrative services or health care services to a Medicare eligible individual under the Medicare Advantage program or Part D program.
Defined as any party that enters into a written arrangement, acceptable to CMS, with persons or entities involved with the Medicare Advantage (MA) benefit or Part D benefit, below the level of the arrangement between an MAO 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.
Defined as any entity that is related to an MAO or Part D sponsor by common ownership or control and (1) Performs some of the MAO 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 MAO or Part D plan sponsor at a cost of more than $2,500 during a contract period.