FDR Program

What is an FDR?

An FDR, short for First Tier, Downstream or Related Entity is a subcontractor of HPSM that is contracted to provide services on behalf of HPSM.

Requirements of FDRs

FDRs must follow HPSM policies and procedures, Code of Conduct, and other requirements. This is a contractual requirement and required by the Medicare program.

These documents specify HPSM’s requirements:

Reporting Potential Compliance Issues

There are a number of ways to report suspected or detected non-compliance or potential fraud, waste and abuse. HPSM has established a confidential Compliance Hotline for HPSM employees, providers, members, FDRs, and other interested persons to report any violations or suspected violations of law and/or HPSM’s Compliance Program.

Compliance Officer

You can call HPSM’s Compliance Officer, Ian Johansson, during business hours to report compliance issues. HPSM’s business hours are 8:00 a.m. to 5:00 p.m., Monday through Friday (except holidays). To report an issue to Mr. Johansson, call  650-616-0050.

Compliance Hotline

The toll-free Compliance Hotline is 1-844-965-1241.

The Compliance Hotline is accessible 24 hours a day, 365 days a year, excluding designated holidays. Callers can report issues anonymously. All reports will be referred to HPSM’s Compliance Officer and investigated.

Compliance Incident Report

To place an anonymous report in confidence, the information you provide will be sent to us by EthicsPoint on a totally confidential and anonymous basis. You have our guarantee that your comments will be heard. Visit  EthicsPoint to make a new report or follow-up on a report you already submitted. 

Executive Order N-6-22

On March 4, 2022, Governor Gavin Newsom issued Executive Order N-6-22 (EO) regarding sanctions in response to Russian aggression in Ukraine.

Download Executive Order N-6-22

Please review the economic sanctions imposed in response to Russia’s actions in Ukraine, including, but not limited to, the federal executive orders identified in the EO, the sanctions identified on the U.S. Department of the Treasury website, and sanctions imposed under state law, if any. Subcontractors of HPSM should be aware of their obligations to comply with the President's and Governor's executive orders, if they hold contracts with any individuals or entities that are a target of economic sanctions.

If you have any questions about this information, please contact HPSM's Compliance Department (Compliance@hpsm.org).