CMS Validation Process: The Silver Lining

We’ve seen quite a few changes over the past few years in the way that the Centers for Medicare & Medicaid Services (CMS) is approaching the program audit and audit validation process. The most notable trend this year is continued push back of responsibility onto the Organization. In recent sanction reports, CMS states that it will require the Organization “to hire an independent auditor to conduct validation in all operation areas cited in this notice and to provide a validation report to CMS.” In addition, CMS presenters at the CMS Fall Conference, which took place on September 11, 2014, stated that “The onus of correction overall is on the sponsor. Therefore, CMS this year will not request universes to conduct sample testing unless the sponsor is unable to demonstrate through its presentation and from the responses to CMS questions, that it has not corrected the findings.”

CMS is sending a clear message here. They expect the Organization, and not CMS, to do the work in the validation process. So, is there a silver lining? Why of course there is.

While it’s clear that CMS is tightening the reins, they are also providing an opportunity – the opportunity to get it right the first time, and not go through the full CMS validation audit process. If you don’t know the best way to proceed, in order to avoid a validation re-audit, we have the roadmap. Contact us today to get started.


While it may be difficult (too much so, for our tastes) for many compliance officers to effectuate the necessary change in the business units, it is not impossible.  Let us help you create a culture of compliance. Visit our website to learn more >>

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