Annual CPE Audit – Compliance as a Strategic Asset

Annual CPE audits are required by CMS, but their value goes beyond compliance. These audits assess the effectiveness of your compliance program, identify gaps, and prevent fraud, waste, and abuse. They also strengthen oversight of delegates and prepare your organization for CMS audits, reducing the risk of penalties and reputational damage. Given the changes CMS announced for 2026 last month, CPE will not be a separate program area of audit focus for CMS, however they are shifting their approach to be more consistent with how compliance oversight is conducted by plans. CMS will pilot this new approach for reviewing CPE during the 2026 audits. While reviewing other program areas of the audit, CMS will have in-depth discussions with the Sponsor about how it prevents, detects, and corrects noncompliance related to the audited program areas, and how the compliance program impacts the Sponsor’s ability to comply with CMS’s requirements during the course of conducting business. During fieldwork, the compliance officer and CMS will discuss monitoring activities conducted for the specific program areas, any noncompliance identified during the CMS program audit fieldwork, and any actionable plans implemented to prevent the noncompliance from recurring. Under this pilot, findings specific to the compliance program structure will generally not be cited. Instead, the Sponsor’s compliance team will work with program area subject matter experts to identify the root cause of noncompliance discovered during the audit and oversee correction to ensure the conditions do not recur.

A strong compliance program builds trust with regulators, members, and partners. It demonstrates integrity and accountability while protecting your organization’s market position. Conducting annual audits and using findings to drive corrective actions and training is essential for long-term success.