Alpha Covenant Holdings · Duty Sheet · generated 2026-10-26 21:04 UTC · free · all sheets

CMS Medicare Advantage / Part D compliance program — first-tier, downstream and related entity (FDR) exclusion screening

Applies to: MA organisations and Part D sponsors, and their FDRs · Rule text: https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-B/part-422/subpart-K/section-422.503

The question the rule asks

42 CFR 422.503(b)(4)(vi) and 423.504(b)(4)(vi): the sponsor's compliance program must include effective measures to prevent, detect and correct non-compliance, including that no employee or FDR is on the OIG or GSA exclusion lists — checked prior to hire or contract and monthly thereafter.

The party this sheet is about

Colonial Pipeline Company · keys supplied: none — exact printed name only · matching: screening-2026-06f: every check is an exact-name (or exact-UEI / exact-NPI / exact-EIN / exact-CIK) lookup against the official file named on the line; nothing is inferred from similar names, owners or affiliates

Receipt r_204d2a10edb047ff · read 2026-10-26 21:04:29 UTC · SHA-256 ec49278fc4d1f6a29d9a751d10b0876d0efc9adf05467d92b41e37dccf3ed115 · verify: https://alphacovenantholdings.com/r/r_204d2a10edb047ff

The official files that answer it, as read on that date

SourceRoleStateRecordsWhat it printed
HHS Office of Inspector General — LEIE (monthly downloadable file)answers the questionanswered0No entry under this exact name in the OIG file fetched 2026-10-25.
SAM.gov Exclusions — Public Extract V2 (GSA, daily)answers the questionanswered0No entry under this exact name/UEI in the SAM extract fetched 2026-10-26 (SAM_Exclusions_Public_Extract_V2_26299.ZIP).
State Medicaid exclusion / termination lists (each state's own published file)supportinganswered0No entry under this exact name/NPI in the 13 state lists read (latest fetch 2026-10-25); 29 state lists are published in forms we cannot read and were not checked.
HHS-OIG Corporate Integrity Agreements (public browse list, exact printed party name)supportinganswered0No corporate integrity agreement under this exact printed party name.

What to record in the file

Monthly LEIE and SAM reads for the FDR's exact legal name and, for individuals, NPI; keep each month's receipt — the hash proves the month's read was not edited later.

What this sheet does not decide

The receipt does not decide eligibility, responsibility, identity or compliance. It records what each official file printed for an exact key or exact printed name on a date. A same-name row is a candidate to be resolved by the reader, not a match. Answering the form's question is the applicant's or reviewer's act; this sheet puts the dated record beside it.

Full receipt (all sources, known limits, print record): screening record · Methodology: https://alphacovenantholdings.com/methodology · Corrections (free, public log): https://alphacovenantholdings.com/corrections