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 (MCA) 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 - The 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.

The Mercy Care Advantage Compliance Program and policies are designed to assist in conducting monitoring and oversight and to help prevent, detect and correct Medicare Part C and D Program non-compliance and fraud, waste and abuse (FWA). Contracted FDRs are required to maintain an effective Compliance Program that includes Standards of Conduct as well as specific policies and procedures that implement the operations of the Compliance Program. Contracted FDRs must have processes in place to prevent, detect and correct identified non-compliance and fraud, waste and abuse (FWA), which includes required disclosure. FDR employees and sub-contractors must abide by federal laws related to the Medicare program as well as CMS rules, regulations and sub-regulatory guidance.

Please review our Medicare Compliance Program to help your organization understand the elements required by CMS for an effective compliance program.  You may also request a copy of our Mercy Care Advantage Compliance policies by sending an email to Wendy Jones at

Medicare Advantage Compliance policies available upon request:
Effective Lines of Communication
Disciplinary Action and Enforcement
Compliance Training and Education
Compliance Monitoring and Auditing
Maintenance and Record Retention
Deficit Reduction Act and False Claims Act Compliance
Federal Disaster or Public Health Emergency Declarations