Medicare Program Audit – Tracer Preparation

Recently, in the Centers for Medicare & Medicaid Services (CMS) National Audit Training sessions which were conducted in August, 2021, Tracer Requirements were addressed.

What is a Tracer?

Per the current CMS Program Audit Process Overview published by the Medicare Parts C and D Oversight and Enforcement Group Division of Audit Operations, the purpose of a Tracer is to allow the organization (Sponsor) to present any information they choose to explain the case selected by the CMS Auditors. In the guidelines, CMS recommends information it expects to see in a Tracer, but CMS doesn’t prohibit the Sponsor from adding information to help the Auditors understand the Sponsor’s processes and successes. CMS is very generous in the time it gives to a Sponsor to present Tracers.

CMS Program Audit Process Overview states:

“While most samples are reviewed at a case level, other samples are reviewed using a tracer methodology. The tracer methodology, used in *CPE, allows sponsoring organizations to tell the story of an issue or policy as it evolves over a period of time.”

* “Compliance Program Effectiveness” (CPE) is a significant portion of the CMS Program Audit which looks at the efficiency, success, and completeness of the Sponsor’s overall compliance program.

Best Practice

During CMS audits, some of the most successful Sponsors use Tracers as an opportunity to “brag” about the good things being accomplished by the Sponsor. They start each Tracer with a strong (and often lengthy) introduction, which describes and “markets” the great qualities and unique or excellent programs the Sponsor has developed and implemented to benefit the members, provide good oversight, and ensure compliance throughout the organization. This positive introduction provides an opportunity to remind CMS of the Sponsor’s strengths.

Please contact us if you have questions, need more information about this guidance, or want a CPE Audit quote today:

Segal Medicare Experts



Resource: Medicare Managed Care Manual, Sec. 50.1.3 – Distribution of Compliance Policies and Procedures and Standards of Conduct (Chapter 21 – Rev. 109, Issued: 07-27-12, Effective: 07-20-12; Implementation: 07- 20-12) (Chapter 9 – Rev. 15, Issued: 07-27-12, Effective: 07-20-12; Implementation: 07-20- 12) 42 C.F.R. §§ 422.503(b)(4)(vi)(A), 423.504(b)(4)(vi)(A)