First Tier, Downstream or Related Entity (FDR) Information

Resources to assist our Delegated Entities

In this section, our First Tier delegated entities can access important information and regulatory guidelines applicable to your Mercy Care and Mercy Care Advantage FDR contracts.


Medicare Managed Care Manual; Chapter 21 Compliance Program Guidelines - Please reference Section 40, Sponsor Accountability for and Oversight of FDRs. This section explains CMS’ expectations of oversight and accountability responsibilities when Mercy Care has delegated administrative or health care service functions under our Medicare Advantage plan contract.

FDR Compliance Packet and Attestation - Mercy Care FDR Compliance packet explains the Medicare Compliance Program requirements that apply to our First Tier delegates, Downstream Entities, and individual employees who perform services for our Medicare Advantage plan contract.

CVS Code of Conduct - Under a Plan Management Services Agreement with Aetna, Mercy Care uses the CVS Code of Conduct to comply with the Medicare compliance program requirements. Contracted FDRs must provide either CVS’s code of conduct and MCA’s Medicare compliance policies or your own comparable code of conduct/compliance policies (collectively, “standards of conduct”) to all employees and Downstream Entities who provide administrative and/or health care services for our Medicare Advantage plan.

MCA Compliance Program and Policies - The MCA Medicare Compliance Program and policies are designed to prevent, detect, and correct Part C and D Medicare Program non-compliance and fraud, waste and abuse (FWA). Policies are as follows: