Medicare Parts C and D plan Sponsors are not required to have a compliance program.

• A. They are required to have a program
• B. They must follow standard guidelines only
• C. They are not required to have a compliance program
• D. They are required to have a program only if required by CMS

Answer: (D)

Understanding how compliance requirements apply to Medicare Part C and Part D sponsors is key. There isn’t a universal mandate that all sponsors must have a compliance program; CMS can require one as part of contract terms or specific guidelines, but it isn’t an automatic obligation in every situation. That conditional nature is why the statement that they are required to have a program only if CMS requires it is the best answer. In other words, a compliance program becomes mandatory only when CMS imposes that requirement; otherwise, it’s not an absolute obligation, though implementing a program is generally prudent to prevent fraud, waste, and abuse and to support contract compliance.