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Program Audit Consistency Teams (PACTs)

By February 9, 2022March 7th, 2022Audits, CMS, Medicaid, Medicare

In the ‘2022 Program Audit Process Overview’1 document, the Centers for Medicare & Medicaid Services (CMS) shared that they will send engagement letters to initiate routine audits beginning February 2022 through July for the 2022 audit year, one month earlier than in years past. With expansion of the window to send engagement letters, we anticipate the 2022 CMS Program Audit season to be another busy one!

With a longer audit timeframe, we expect CMS to need additional auditors to assist with conducting program audits. More audits and auditors increase the opportunities for auditor variability and potential audit condition classification inconsistency. CMS is aware of this variability and has taken steps to ensure consistency in classification of audit conditions.  One of these steps is the creation of ‘Program Audit Consistency Teams’, also known as PACTs.  PACTs include subject matter experts on the different audit program areas as well as audit policy experts and are engaged during the ‘Audit Reporting’ or third phase of the audit.

Preliminary draft report findings are reviewed during Phase III and are subject to additional review and evaluation after all supporting documentation has been received and evaluated. It is at this point that audit condition classification occurs.  All audit findings continue to undergo review and evaluation by PACTs to ensure a fair and consistent outcome across all audits.

CMS’s goal is to continue enhancing the consistency among audits and strengthen its audit teams’ expertise.

1 2022 Program Audit Process Overview updated December 2021 and available @

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