Centers for Medicare & Medicaid Services (CMS) requires health plans and its First-Tier Downstream Related entities (FDRs) to comply with specific annual compliance program. My organization is a FDR of Optum and am therefore required to train and attest annually. 
The provided links to 2022 courses enable us to meet the requirements in the event my organization does not already have one in place. 

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My organization requires all employees to complete the following items or an equivalent within 90 days of hire and annually thereafter.

A. OIG-GSA Exclusions:
My organization ensures that none of our employees, contractors or downstream entities that service Optum/UHG business are on the HHS Office of Inspector General (OIG), the General Services Administration (GSA), System for Award Management (SAM) exclusion lists, or any applicable state exclusions lists prior to hire, or contracting, and monthly thereafter. Documentation of pre-hire/contract and monthly screenings are maintained for at least 10 years.

B. Offshoring:
My organization does not engage in offshore operations for Optum related Medicare business without the express consent of an authorized Optum representative since these activities, if involving the receipt, viewing, processing, transferring, handling, storing or accessing of PHI, must be reported to CMS. Optum either has already been notified of any such offshore arrangements, or we will notify as necessary by completing the FDR Offshore Sub-Contractor Attestation form and submitting to

C. Compliance Officer/Representative:
My organization maintains a designated compliance officer or representative.

D. Indicate the Date and Time of Attestation below, then move on to Steps 2A and 2B.


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A. I attest that my organization has provided this training, or an equivalent, and has met the requirements above for all our employees, contractors, and downstream entities in 2022 and maintain records of completed training for at least 10 years.

B. Check the box next to "I Agree" statement.

Please contact if you have any questions.

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* 3. Unique 4-Digit ID # in XXXX format

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* 4. Vendor / Practice Name

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* 5. Your Name

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* 6. Email Address

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* 7. Your Phone Number