Post-Valentine’s Day present from CMS: the first 2017 audit notices
By Julie Mason
Today at the annual HCCA Managed Care Compliance Conference in sunny and warm Scottsdale, AZ, the new director of CMS’ Medicare Parts C and D Oversight and Enforcement Group (MOEG), Vikki Ahern, announced that the first round of 2017 CMS program audit notices will be sent starting February 21 for early April audit start dates. Although CMS has not yet released the final 2017 program audit protocol (after two rounds of public comments, the final draft is currently with the Office of Management and Budget for approval), it is expected to be released imminently. Although one can expect that the final audit protocol will be released prior to CMS sending the first of this year’s audit notices, the very first few plans to receive audit notices may have only a short period (weeks or even days) to review the new protocol before receiving their audit notice. The only sneak previews of the final audit protocol provided by Ms. Ahern are changes to the Compliance Program Effectiveness protocol, including the move to only three audit elements (prevention, detection and correction of compliance and FWA issues), rather than the previous seven, which were based on the seven required compliance program elements; several questionnaires to be used for onsite interviews of senior management; and the removal of the Fraud, Waste and Abuse Monitoring (FWAM) universe. Several of these were included in some form in the draft 2017 protocol, but the details may have changed from draft to final version.
Despite a lot of uncertainty throughout the federal government in these tumultuous early days of the new administration, CMS is moving full steam ahead with its auditing efforts and there is no evidence on the horizon that those efforts will be curtailed in 2017. All Medicare plans would be well advised to keep an eye out for the final protocol, disseminate it to relevant staff upon release, and implement the changes as soon as possible.
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