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First Tier, Downstream and Related Entities (FDR) …

Quality health plans & benefitsHealthier livingFinancial well-beingIntelligent solutionsFirst tier , Downstream and Related Entities (FDR) Medicare Compliance Program GuideMarch B (3/17)2 Our Medicare compliance program helps us serve our members ethicallyWe re committed to practicing business in an ethical manner. Our Medicare compliance program helps to: Reduce or eliminate fraud, waste and abuse (F WA) Make sure we comply with applicable laws, rules and regulations Reinforce our commitment to compliance We use external Entities to bring our members cost-effective health care solutions Aetna Health Inc., Aetna Life Insurance Company and affiliates (Aetna) offer Medicare Advantage (MA), Medicare-Medicaid Plans (MMPs) and Medicare prescription drug plans (collectively, Medicare plans ).

3 II. What’s an FDR? We use the current CMS definitions to define First Tier, Downstream and Related Entities: First Tier Entity is any party that enters into a …

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