CareSource, referred to as “the Company,” must ensure its First Tier, Downstream and Related (FDR) entities have read and understand all requirements pertaining to the regulations for services that are performed by workers located in Offshore countries, regardless of whether the workers are employees of American or foreign companies. Consistent with direction from the Centers for Medicare and Medicaid Services (CMS), this applies to entities the Company contract or sub-contract with to receive, process, transfer, handle, store, or access beneficiary protected health information (PHI) in oral, written or electronic form.

In the event an FDR sub-delegates any of the Company’s Medicare activities to an Offshore subcontractor, the below form must be completed. CMS defines an “Offshore Subcontractor” as follows:

The term “subcontractor” refers to any organization that the Company contracts with to fulfill or help fulfill requirements in their Part C and/or Part D contracts. Subcontractors include all first tier, downstream, and/or related entities. The term “offshore” refers to any country that is not one of the fifty United States or one of the United States Territories (American Samoa, Guam, Northern Marianas, Puerto Rico, and Virgin Islands). Examples of countries that meet the definition of “offshore” include Mexico, Canada, India, Germany and Japan.

Subcontractors that are considered offshore can be either American-owned companies with certain portions of their operations performed outside of the United States or foreign-owned companies with their operations performed outside of the United States. Offshore subcontractors provide services that are performed by workers located in offshore countries, regardless of whether the workers are employees of American or foreign companies.