Medicare Parts C and D 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)

Compliance program requirements for Medicare Part C and Part D sponsors are not universal; they depend on what CMS mandates for a given contract or program year. CMS can require a sponsor to have a formal compliance program as a condition of participation or contract approval, but if CMS does not impose that requirement, there isn’t a mandatory obligation to establish one. This makes the statement that a program is required only if CMS requires it the most accurate reflection. While having strong internal controls and following general best practices is always wise, the binding requirement comes from CMS directives, not from an automatic rule applying to all sponsors.