VillageMD has contracts with the Centers for Medicare and Medicaid Services (CMS) to provide certain services to Medicare beneficiaries. VillageMD delegates some of the administrative and clinical services required under these contracts to third-party vendor, known as delegated entities. CMS refers to these entities as First-Tier, Downstream and Related entities (FDRs). FDRs are an important part of VillageMD’s Compliance Program. If you or your organization are considered an FDR under CMS guidelines certain policies and rules apply to you.

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Code of Conduct

Each FDR is required to have a Code of Conduct which outlines their commitment to Compliance. VillageMD’s Code of Conduct can be found here. We want to ensure our partners follow and understand the laws, regulations, and policies that apply to our business.

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Annual Training

Each FDR is required to ensure that their staff are trained in the following areas:

• General Compliance Training
• Fraud, Waste and Abuse
• Privacy

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FDR Document Retention

FDRs are required to retain all Medicare documentation and maintain evidence for at least 10 years. This includes any documentation related to services the FDR performs for VillageMD, including documentation related to:

• Training certificates, attestations, or employee logs
• Code of Conduct and/or compliance policies distribution and updates
• OIG and GSA exclusion screenings
• Reports of and responses to suspected noncompliance and/or fraud, waste, or abuse
• Auditing and monitoring activities

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Reporting Compliance or Fraud, Waste and Abuse (FWA) Concerns to VillageMD

Reporting is vital in preventing, detecting, and correcting of noncompliance and FWA. VillageMD has safeguards in place that protect any individual who reports a concern in good faith from retaliation. FDRs are expected to have safeguards in place as well.

If any FDR or FDR employee knows of, or suspects, an issue of noncompliance or potential FWA, they are required to report the incident to VillageMD.

Report Directly to VillageMD Compliance: compliance@villagemd.com

Report Anonymously to: (855) 236-0714

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OIG and GSA SAM
Exclusion List Screening

Federal law prohibits Medicare and other federal health care programs from paying for items or services provided by an individual or entity excluded from participation in these federal programs. Therefore, before hiring or contracting and monthly thereafter, each FDR must check exclusion lists from the Office of Inspector General (OIG) List of Excluded Individuals and Entities (LEIE) and General Services Administration (GSA) System for Award Management (SAM). The following individuals and entities must be screened: employees, temporary employees, volunteers, consultants, and members of your governing board. Completing these screenings will confirm your employees and Downstream entities aren’t excluded from participation in federally funded health care programs.

FDRs may use these websites to perform their exclusion list screenings:

• OIG List of Excluded Individuals and Entities (LEIE)
• GSA System for Award Management (SAM)

FDRs must maintain evidence that they’ve screened against both exclusion lists and keep proof of screenings for a minimum of 10 years.

If an FDR discovers an employee or Downstream entity on one of these exclusion lists, it must immediately remove the employee or Downstream entity from work directly or indirectly related to VillageMD and report immediately to: compliance@villagemd.com