It’s the Most Wonderful Time of the Year…To Think About Your 2019 CPE Audit

For most Plan Sponsors, the holidays are not a time of respite or reflection; they are a time for looking forward to the upcoming calendar year. This is when Compliance begins its tradition of annual audit work plans and getting those audits approved via committee and the governing body. While in the midst of all this planning, it’s important not to overlook your annual compliance audit.

As you know, the Centers for Medicare & Medicaid Services (CMS) requires that Plan Sponsors annually complete an independent audit of their compliance program effectiveness (CPE). Ensure you include this audit in your work plan as well as allocating the funds in your budget for an external resource. Gorman Health Group can help! We conduct these audits following the CMS audit protocol methodology. Current protocols dictate:

  • Document review
  • Interviews
  • Tracer samples (6)
  • Training/exclusion monitoring samples (20)

We can tailor this process to best fit Plan Sponsor needs. Though CMS requires the annual audit, they do not dictate its methodology. Contact us today to learn how we can support your compliance program audit needs.


Gorman Health Group has years of experience performing in-depth CPE assessments as well as audits using the CMS protocol methodology, and many of our subject matter experts are certified by the HCCA and AHIP. Contact us today for more details.



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Tina Bailey
Tina Bailey

Vice President, Compliance Solutions

Tina Bailey began her tenure at GHG in 2011 and was appointed Vice President, Compliance Solutions in August 2018. In this capacity Tina leads the Compliance Solutions team and its engagements to ensure optimum solutions. Tina brings GHG clients more than 25 years of experience, providing them a knowledgeable resource in Medicare Advantage and Part D with an emphasis on Special Needs Plans (SNPs). Her areas of expertise include compliance, applications, audits, readiness, delegation oversight, marketing materials, bid development, new plan implementation as well as appeal and grievance expertise. Prior to her role at GHG, Tina held a management position with a SNP where she was responsible for the organization's day-to-day Medicare operational compliance. Tina has also held management positions with several MAOs in the greater Los Angeles and Orange County markets. In her previous roles, Tina was responsible for compliance interpretation and implementation, member/marketing material review and submission, bid development and submission, internal audits and CMS audit preparation, implementing internal corrective action plans, and creating detailed trainings. Tina is certified in Compliance and Ethics from the Health Care Compliance Association.

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