On February 8, 2019, CMS released “CMS Program Audits Frequently Asked Questions (FAQs). One of the questions addressed was:
“Will sponsoring organizations always have the opportunity to submit universes up to three times during a program audit?”. CMS’ response was “No. Three attempts may not always be feasible depending on when the data issues are identified and the potential impact to the audit schedule (e.g. sponsoring organizations will not be allowed to resubmit universes after auditors have shared timeliness test results with the sponsoring organization).”
This gives Plans yet, another reason to ensure universes are accurate.
BluePeak can review your data and coach your team to help them produce accurate and complete universes with our Universe Monitoring Services. Since 2013, BluePeak has completed over 150 CMS mock audits and onsite support projects, and we’ve observed that many plans still struggle with pulling and populating universes correctly. Plans who are unable to produce accurate and complete universes after three tries (or fewer as noted above) receive an Invalid Data Submission condition that counts toward their overall CMS program audit score.
Whether you receive a CMS audit engagement letter in the near future or manage to avoid one this audit season, only to receive an Appeal Timeliness Monitoring notice, you do not want to be pulling and reviewing universe data for the first time upon receipt of such a notice.
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