The Centers for Medicare & Medicaid Services (CMS) mandates that plan sponsors administering a Medicare Advantage program or Medicare Part D prescription drug plan must implement an effective compliance program that meets the regulatory requirements set forth in 42 C.F.R. §422.503(b)(4)(vi) and 42 C.F.R. §423.504(b)(4)(vi).  In addition, Plan Sponsors must ensure its first tier, downstream, and related entities (FDR) have an effective compliance program which includes:

  • Policies and procedures for preventing fraud, waste and abuse;
  • Policies and procedures for avoiding conflicts of interest;
  • Training and education on applicable Medicare Part D laws, rules, regulations and CMS guidance.

As the administrator of transplant services on behalf of either a Medicare Advantage or Medicare Part D prescription drug plan, Tethys has been delegated the responsibility of ensuring that its participating network facilities, pharmacies, vendors and subcontractors are in compliance with the applicable laws, Medicare Part D regulations, and CMS guidance.


For more information on FDR compliance visit The Medicare Learning Network Compliance Page or view the CMS’ Compliance Program Guidelines and Prescription Drug Benefit Manual