Top 10 Audit Tips

Here are some tips to help ensure your Plan is adequately prepared as audit season gets underway for 2021.

1. Ensure your plan and all of its delegates can produce accurate universes, without delay.  If you are not already producing and reviewing universes on a regular recurring basis, start doing so now.
2. Have a plan for resources and have a contingency plan.   Audits tend to happen at the worst possible time, like when a key resource may be unavailable. Know who your ideal audit support team is and identify back-ups. You should make sure your delegates have a similar plan too.
3. It is not too late to do a mock audit.   Mock audits are a great way to test for issues and know where your Plan’s areas of weakness (or strength!) reside. This enables your Plan to detect and correct issues before CMS has a chance to find them.
4. Make sure your plan is familiar with the 2020 protocols.  While the audit protocol changes were not extensive, you will want to be familiar with the new audit protocol expectations.
5. Familiarize yourself with the recently published CMS Program Audit FAQs. CMS published this helpful guide in February 2019 in which CMS provided answers to the Program Audit questions they received most frequently in 2017 and 2018.
6. Think past the audit.  There will likely be findings which could result in Immediate Corrective Action Plans (ICAR), Corrective Action Plans (CAR), remediation, clean periods, and validation audits. BluePeak offers training on how to write effective Corrective Plans, managing remediation efforts, and what to expect during an Independent Validation Audit. Think about training now so that you and your team are prepared.
7. Be prepared to navigate employees in multiple locations.   . Many plans and their delegates may still be working from home during a program audit. Plan ahead and review what technology will be used for communication and coordination.
8. Know your vulnerabilities. Think of the issues your Plan has encountered over the course of the past year. Those issues are likely going to come up during a program audit. Spend time now thinking through how you’ll explain the issue to auditors and ensure you have documentation of actions taken.
9. Get your Compliance Program Effectiveness documentation ready. Rather than waiting until you receive an audit notice, review, and refresh your responses now to the Compliance Officer, FDR Oversight, and SIU/FWA Questionnaires. Also, dust off that Organizational Structure Governance presentation and ensure it is audit ready.
10. Inventory actions taken in response to COVID-19. CMS will likely ask about the permissive actions your Plan has taken in response to the pandemic. Be sure there is a clear understanding of what actions your Plan has elected to take, why, and when those actions were taken.