Program Audit Changes
- Modifications have been made to the universe timeliness test and universe submissions
- Compliance Program Effectiveness (CPE)
- The 7 elements will be tested with five tracer samples
- Two new test elements will be piloted starting mid-year
- Medication Therapy Management (MTM)
- Provider Network Adequacy
- Timing has been modified for the program audit
- CMS expects correct universes submitted in a timely manner
- Beneficiary impact analysis
Enforcement Actions 101
- We all know that the penalties can:
- Include Civil Money Penalties (CMPs),
- Intermediate Sanctions (suspension of enrollment, marketing, payment), or
- CMS can determine that the infraction may cause termination from the program
- Imposed at the contract level on Medicare Advantage, Prescription Drug, PACE, or Cost Plan contracts
Don’t miss this opportunity to engage with CMS 2015 Audit Protocol.