The Centers for Medicare and Medicaid Services (CMS) and federal and state regulators take protection of their consumers seriously, and they pass that responsibility to our organization when we are acting in their capacity as a CMS contractor or plan sponsor. CMS and state regulators hold our organization directly accountable for delegate activities and performance.
As part of an effective compliance program, CMS and other federal and state regulators require that UnitedHealth Group and its affiliate organizations (collectively, our organization) communicate and monitor specific compliance and fraud, waste and abuse requirements to our employees and delegated entities (delegates) – including first tier, downstream and related entities (FDRs). In the event of a CMS, federal or state audit, our organization must demonstrate that we evaluate our delegates’ compliance with program requirements, including effective monitoring and oversight of such delegates.
Our organization uses the terms: delegates; delegated entities; vendor; first-tier, downstream entity and related entity (FDR); subcontractor; and, occasionally, others interchangeably to name the parties with whom we contract with to support administration of benefits, access to care and other services performed on our behalf.