Lead the way - Aetna

Quality health plans & benefits Healthier living Financial well-being Intelligent solutions First Tier, Downstream and Related Entities (FDR) Medicare Compliance Program Guide March 2018 B (3/18) I. Introduction Aetna s Medicare compliance program Aetna s reputation as an industry leader depends on our ability to deliver on our promises. For more than 160 years, we ve been guided by the highest standards of integrity. Our relationships with our customers, business partners and suppliers are built on trust earned over time and through experience. Each day, we must remember our commitment to do the right thing for the right reason and keep the people we serve at the center of everything we do. When we act with integrity, we are living the Aetna Way. Our Medicare compliance program helps us serve our members ethically We re committed to practicing business in an ethical manner.

organization or Part D plan sponsor or applicant. These arrangements provide administrative or health care services to a Medicare-eligible individual under the MA program or Part D program. A downstream entity is any that enters a written arrangement, acceptable to CMS, with persons or entities. These persons or entities are involved with

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