2018 Audit & Enforcement Conference: Program Audit Changes on the Horizon

On Monday, I provided some highlights of last week’s conferences during our weekly Insider call. The Centers for Medicare & Medicaid Services (CMS) hosted the Spring Conference on May 9 and the Audit & Enforcement Conference on May 10. The Program Audit tools and methodology continue to evolve. The agency gave the industry a heads up about the changes when the data collection tools were posted for public comment. Today I focus on one session, New Approach to 2019 Audits and Universes.

Before the 2019 proposed changes, protocols were made up of audit process and data request documents and questionnaires. CMS also maintained internal information such as how samples are targeted and how Compliance Program elements are assessed. I have outlined some highlighted points from the session:

  • CMS refers to the data collection tools as the “what” and refers to the audit process documents as the “how.” Going forward, the industry should see the data request documents released for public comment and the reformatted audit process documents posted on CMS’ Compliance and Audits
  • Gone are the Excel impact analysis documents. Instead, CMS will follow the universe record layout for requesting impact data in an effort to make audits more efficient.
  • Root cause analysis is still of paramount importance to the agency. Often we see why a specific case fails during a webinar, but determining the overall issue beyond the case-level detail of failure will still be requested.
  • Timeliness metrics will be broken out; for example, ODAG timeliness will be evaluated, and sub-element results will be provided such as timeliness of notification. This change could help sponsors better identify root cause and correction steps.
  • In addition to the arguably broadest change of consolidating certain CDAG and ODAG universes (still separated by Part C and Part D), the agency removed data points that were no longer meaningful and removed questionnaires that were no longer necessary or were not being used as intended.
  • Universe integrity will be extended to all program audit areas. In 2018, the agency will pilot this in a few audits. We expect this to add additional webinar time for the agency, plan sponsors, and delegates. For data integrity webinars, the agency will still select five cases of standard and five cases of expedited (for a total of 10), even though the two case types will be in one table.

Normally, the video recordings would have been posted by this point. However, the agency notes it has a new process for releasing and posting the videos. Once management approval is obtained, registered participants will be notified when the videos are available for viewing. If you were not registered for the conference, periodically check the “Event Archive” webpage for updates. Stay tuned to this page for more insight on these conferences and other agency activity.

 

 

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Regan Pennypacker
Regan Pennypacker

Regan is Senior Vice President of Compliance Solutions at Gorman Health Group (GHG). She leads the Compliance Solutions practice, responsible for multidisciplinary projects such as Part C and Part D audits, new applications, marketing material reviews, risk assessments, and training engagements. As a member of this team, she has provided compliance direction and insight on industry best practices to many GHG clients. Regan brings GHG clients 19 years of experience in the healthcare industry. Read more

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