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First-Tier, Downstream and Related Entities (FDR) Compliance Program and Attestation Requirements

The Medicare Compliance Program requirements described herein apply to all participating Providers contracted with NationsHearing to provide services to Medicare participants. This includes audiologist, hearing aid specialist, hearing aid dispensers, hearing instrument specialist, and other provider types.

Introduction – FDR (Provider) Compliance

NationsHearing is considered a First-Tier entity as we provide administrative and health care services for Medicare plans. As a First-Tier entity, we are responsible for complying with relevant Medicare program requirements. We must also ensure that our Downstream Entities, comply with applicable laws and regulations, including the requirements outlined below. If you or your organization is contracted or intends to contract with NationsHearing for participation in our Provider network, you are considered an FDR (specifically, Downstream Entity of NationsHearing) under CMS guidelines.

Compliance Program and Annual Attestation Requirements

Your organization must comply with NationsHearing compliance program requirements. This summarizes the compliance program requirements. NationsHearing obtains an annual attestation from our Providers to ensure compliance with applicable program requirements. An authorized individual must attest that its organization is in compliance with requirements relating to the following:

  • Completion of CMS’ general compliance and fraud, waste, and abuse (FWA) training
  • Code of Conduct and compliance policies and maintain record of distribution
  • Federal exclusion list screenings (OIG/GSA) and maintain record of timely checks against those lists
  • The availability of a system to receive reports of suspected non-compliance and/or FWA that is confidential, allows anonymity, and includes policies of non-retaliation
  • Record Retention for 10 years
  • Monitoring and oversight
  • Identification of offshore operations

You may be asked to provide evidence of compliance. In addition to completing an attestation, NationsHearing may request that you provide evidence of your compliance. This is for monitoring/auditing purposes. We take these responsibilities seriously. If you have questions or concerns about these compliance program requirements, just contact NationsHearing.

The “Toolbox of Resources” may help you meet these requirements.

Toolbox of Resources for Providers (FDRs)

General compliance and FWA training

CMS general compliance training module

You can find the CMS general compliance training module on the CMS Medicare Learning Network (MLN). It can be completed on the MLN, after registration. It is titled Medicare Parts C and D General Compliance Training. You can also download it and incorporate the module, unmodified, into your existing training materials/systems.

CMS FWA training module

You can find the CMS FWA training module on the MLN. It can be completed on the MLN, after registration. It is titled Combating Medicare Parts C and D Fraud, Waste, and Abuse Training. You can also download it and incorporate the module, unmodified, into your existing training materials/systems.

Proof of training completion

CMS requires FDRs to maintain evidence of training completion. FDRs must retain this evidence for 10 years. The CMS training completion certification is evidence of completion. This sample log also provides a way to document your employees’ completion of training.

Who should complete training?

Not every employee always needs to complete training. This grid has examples of FDR employees that do and don’t need to complete it.

Code of conduct and compliance policies

Don't have your own code?

Feel free to distribute NationsHearing’s code of conduct to your employees.

Medicare compliance department policies

NationsHearing’s code of conduct explains our compliance program, but contact for policies that provide more detail about our Medicare compliance program.

Exclusion list screenings

Where is the OIG?

Complete OIG exclusion list screenings before hiring/contracting and monthly after that for your employees and Downstream Entities.

Where is the GSA’s SAM?

Complete the GSA’s SAM exclusion list screenings before hiring/contracting and monthly after that for your employees and Downstream Entities.

Reporting mechanisms

How do I report non-compliance or potential FWA to NationsHearing?

This poster provides ways for reporting issues directly to NationsHearing. Feel free to share this throughout your organization so that your employees know how to report concerns. Remember, you must report suspected or detected noncompliance or potential FWA that impact Medicare Health Plans.

Monitoring and oversight

Downstream Entity oversight

You must conduct oversight of your Downstream Entities. This may not be applicable to all Providers / FDRs.

Annual Attestation

FDR Annual Compliance Attestation

Submit the Medicare Compliance Program Guidelines Attestation for Downstream Entities (Providers) to or through our Portal, upon NationsHearing’s request. This attestation must be completed by an individual in your organization who has signatory authority to make the representations in the attestation.

Other tools

Offshore attestation form

Use this form to request permission for you or your subcontractor to use an offshore individual or entity to perform services that involve the processing, transferring, handling, storing or accessing of Medicare member PHI. Return the completed form to

More tools

If you have ideas for tools that would help you in meeting the Medicare compliance program requirements, send an email to


If you have a question that we didn’t answer in this guide, please contact

Reference Resources

CMS and Federal online resources

CMS provides a variety of Medicare and Medicaid related educational tools and other resources at Below are some links to the tools/resources applicable to FDR requirements:

Reporting FWA and Compliance Concerns

Reporting Mechanisms

NationsHearing has safeguards in place that protect any individual who reports a concern in good faith from retaliation. To the extent possible, reports are kept confidential and anonymous reporting is available through the NationsHearing Compliance hotline.

By Phone

Call the NationsHearing Compliance Hotline Toll-free (877) 391-1553

By Email


Write to NationsHearing’s Compliance Department at:
NationsHearing, LLC.
Attn: Compliance Department
1700 North University Drive
Plantation, FL 33322

Questions / Concerns

Contact Information

For compliance questions or concerns, you can call or email NationsHearing’s Compliance Department at (954) 939-3299 or