• FDR Compliance Guide & Attestation

FDR Compliance Guide & Attestation

First Tier, Downstream, and Related Entities (FDR)

Senior Whole Health relies on our contracted providers and other contractors to help us meet the needs of our membership according to Medicare Advantage/Medicare Prescriptions Part D program requirements. These individuals and organizations are considered First Tier, Downstream, and Related Entities (FDRs). FDRs are individuals or entities to which Senior Whole Health has delegated administrative or healthcare service functions relating to the Senior Whole Health Medicare Advantage contract with CMS.

Under your contract with SWH you are required to have in place Standards of Conduct, Compliance Policies, and compliance reference materials. You may also choose to use The Senior Whole Health FDR Compliance Guide to disseminate to all employees and contractors for meeting the requirements. Additionally, you and your employees and contractors will need to take the CMS standardized General Compliance and Fraud Waste and Abuse Training if you are not “deemed”. This is all explained in the Compliance Guide.

FDR Compliance Guide

The purpose of this Compliance Guide is to assist FDRs in understanding and meeting their compliance obligations under the Senior Whole Health Compliance Program.

Download the FDR Compliance Guide (PDF).

Download the FDR Reporting Poster (PDF).

Annual Fraud Waste and Abuse Training for Providers

Click here to visit the standardized web-based training module developed by CMS.

Click here to view information about False Claims Act laws. Senior Whole Health encourages you to report fraud or suspected fraud by calling our fraud hotline at 1-800-341-4915, our anonymous compliance hotline at 800-915-2108 or the Main SIU Hotline at 1-800-755-0850.

Annual Compliance Attestation

Senior Whole Health has developed an annual attestation as part of its efforts to validate that each contracted FDR has met CMS requirements.

Please return your completed and signed FDR Annual Compliance Attestation each year by December 31st.

Completed attestations can be emailed to This email address is being protected from spambots. You need JavaScript enabled to view it.. This is the preferred method or mail your completed Compliance Attestation to Senior Whole Health, Compliance Department, Attn. Catherine Jason, 58 Charles Street, Cambridge, MA 02141. 

Download the FDR Annual Compliance Attestation (PDF).

Compliance Policies and Resource Documents

Fraud Waste and Abuse Reporting Policy

Code of Conduct

Compliance Program

Magellan False Claims Act Policy

Magellan HIPAA Compliance Statement



Last Updated 12/06/2018