Healthfirst First Tier, Downstream, and Related Entity and Affiliate Compliance Attestation

Healthfirst’s commitment to compliance includes ensuring that our First Tier, Downstream and Related Entities (FDRs) are in compliance with applicable state and federal regulations. Healthfirst contracts with FDRs to provide administrative or healthcare services to our enrollees; we are ultimately responsible for fulfilling the terms and conditions of our contract with the Center for Medicare & Medicaid services (CMS) and meeting the Medicare and Medicaid program requirements. Therefore, Healthfirst has developed a process to validate that each contracted FDR and Affiliate has met the requirements. Each FDR and Affiliate must complete the Attestation below, to confirm compliance with the Healthfirst FDR compliance requirements.

An FDR is a First Tier, Downstream or Related Entity. An FDR provides administrative or health care services relating to Healthfirst Medicare contracts. Healthfirst’s FDRs include hospitals, providers, ancillaries, and some vendors.

First Tier Entity: any party that enters into a written arrangement, acceptable to CMS, with an MAO or Part D plan sponsor or applicant to provide administrative services or health care services to a Medicare eligible individual under the MA program or Part D program.

Downstream Entity: any party that enters into a written arrangement, acceptable to CMS, with persons or entities involved with the 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.

Related Entity: 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.

An affiliate is a person, provider or entity who provides care, services, or supplies under the Medicaid program, or a
person who submit claims for care, services, or supplies for or on behalf of another person or provider for which the
Medicaid program is or should be reasonably expected by a provider to be a substantial portion of their business

The FDR and Affiliate Requirements are detailed in the FDR and Affiliate Compliance Guide PDF.

The requirements include:

  • Distribution of Code of Conduct and Compliance Policies
  • Exclusion Screening
  • Fraud, Waste, Abuse and Compliance Concerns Reporting

In addition, all FDRs must complete the Compliance Attestation Form below annually.

Compliance Attestation Form


This form must be completed by an authorized representative (i.e., a Compliance Officer, Chief Medical Officer, Practice Manager/Administrator, an Executive Officer, Provider, or Owner) to attest to compliance with the Healthfirst FDR and Affiliate Compliance Policy annually.

Step One: Click each of the links below and select the appropriate response for each category. All four items must be completed. Please check one box in each category.

I have reviewed and understand the Healthfirst FDR and Affiliate Compliance Guide. My organization will abide by the Healthfirst compliance policies. In addition,

Below are links to the exclusion screening websites:

Step Two: Complete the Attestation below.

I certify, as the authorized representative having responsibility directly or indirectly for all employees, contracted personnel, providers/practitioners, and vendors who provide health care or administrative services under Medicaid and/or Medicare, that the statements above are true and correct to the best of my knowledge. In addition, my organization agrees to maintain supporting documentation for a period of 10 years and will furnish evidence of the above to Healthfirst upon request for monitoring and auditing purposes.

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If you have any questions, please contact the Healthfirst Compliance department at or 1-212-324-2699.