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First Tier, Downstream or Related Entity (FDR) – CMS compliance attestation

In accordance with the Centers for Medicare and Medicaid Services (CMS) regulations, Geisinger Health Plan requires your company to fulfill and attest to meeting requirements in the following areas:

Geisinger Health Plan Code of Conduct

  • Communicates GHP's compliance expectations 
  • Your own organization's standards of conduct may be used if it meets all CMS requirements 
  • Code of Conduct must be distributed to each of your employees within 90 days of employment and annually thereafter

OIG/GSA exclusion list checks

  • Performed for all employees, pharmacies, vendors, board members or related individuals and entities
  • Performed prior to hire or engagement start date and monthly thereafter

Review exclusions list