Healthfirst's December 31 Compliance Deadline Is More Than One Attestation
10/05/2026
What changed
Healthfirst is reminding participating providers that required annual compliance activities must be completed by December 31, 2026.
The requirements are not identical for everyone in a practice. Healthfirst identifies several categories of individuals and entities that have separate obligations.
First Tier, Downstream and Related Entities must complete the FDR Compliance Policy attestation through HealthfirstFDR.org. The form must be completed by an authorized representative, such as a Compliance Officer, Chief Medical Officer, Practice Manager or Administrator, Executive Officer, provider or owner.
Healthfirst also requires Cultural Competency Training and Attestation from participating providers and office staff who have regular and substantial contact with Healthfirst members.
For qualified contracting providers participating in Medicaid Managed Care organizations, including managed Long Term Care Plans, Healthfirst requires certification that an effective compliance program has been adopted and implemented.
Providers involved in the routine care of Healthfirst Special Needs Plan members — including members of the Life Improvement Plan, CompleteCare and Connection plans — have an additional requirement: Special Needs Plan Model of Care training. Healthfirst says this training applies to providers, delegated vendors and appropriate staff.
Why it matters for your practice
The December 31 deadline is easy to read as one annual compliance task. Healthfirst's requirements show that it is more complicated than that.
A practice can have several providers participating in different Healthfirst arrangements, while administrative and clinical staff can have different responsibilities. Completing one attestation therefore does not necessarily satisfy every applicable requirement.
The distinction matters because these activities are not necessarily handled through the same process or by the same person. A provider may need to complete one requirement, while a Practice Manager or another authorized representative completes another.
This also means that a practice should not wait until the end of December to determine who is responsible for what. The deadline is the same, but the requirements are not.
What to do — and what not to do
- Review the Healthfirst requirements by provider, staff role and applicable plan participation.
- Create a record showing which requirement applies to each person and retain the applicable confirmation, attestation or training documentation after completion.
- Do not treat “Healthfirst compliance” as one practice-wide checkbox.
- Healthfirst directs providers with questions to their network account manager or Provider Services.
If your practice needs assistance coordinating these attestations and maintaining the related documentation, WCH can help with the process.