Preparing for Your CPE Audit

by:  Sarah Lorance

Segal Medicare Experts Senior Vice President

It’s never too early to prepare your organization for an audit, especially a Centers for Medicare and Medicaid Services (CMS) Compliance Program Effectiveness (CPE) audit. While it is a best practice to document and maintain CPE documentation throughout the year, don’t stress if this didn’t happen – Segal Medicare Experts (SME) is here to help!

CMS selects Sponsoring Organizations (SOs) for program audits between March and July each year. It’s important to keep in mind that CMS can select an SO for an ad hoc audit anytime during the year. Regardless of what kind of audit for which you may be selected, the key is being always prepared.

The program area(s) selected for audit depend on the SO’s specific plan types. The CPE area is applicable to every SO and a critical component to demonstrating to CMS the strength of your overall Medicare program.

Within the CPE audit, CMS will be assessing the SO’s:

Prevention controls and activities – Processes, metrics, and oversight activities in place to identify a trend towards                  noncompliance as well as intervention taken to correct and/or mitigate.

Detection controls and activities – Processes, metrics, and oversight activities to internally identify noncompliance in a timely manner.

Correction controls and activities – Processes to quickly respond to noncompliance, including root cause analysis, impact assessment, communication, and corrective action.

There are several ways CMS assesses these controls and activities, as well as elements of an SO’s compliance program. Through a combination of documents, questionnaires, overview presentations, work plans, organizational charts, risk assessments, data universes, reporting, and interviews, CMS will gain a comprehensive understanding of the effectiveness of your compliance program.

Engage Segal Medicare Experts to assist in focused mock reviews. We help numerous SOs prepare for CPE audits and understand how to communicate processes clearly and comprehensively. This includes the type of documentation CMS expects to see, how to effectively compile narratives, and providing interview preparation tools and sessions.

By investing the time and energy now into preparing your organization, you will be ready to demonstrate to CMS the strength of your compliance program when your CPE audit notice arrives.

If you have questions and/or want a CPE Audit quote, please contact us:

Segal Medicare Experts or 562.498.2218