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The 2019 CMS Program Audit Season is Upon Us!

CMS started issuing audit letters in March and will continue doing so through July. If you haven’t already received an audit notice, what are you doing to prepare?

2019 starts the newest Program Audit cycle and while there were minimal changes to the 2019 Program Audit Protocols, BluePeak is expecting significant changes for 2020 and will update you on those changes this Spring.

The changes to the 2019 Protocols are listed below:

→ Suspension of the CDAG, ODAG and SARAG Supplemental Questionnaires

→ Suspension of Call Log Universes for CDAG and ODAG

  • CMS will review Plan’s oversight of call routing as part of the CPE review

→ Suspension of the CPE self-assessment questionnaire

→ Removal of the Contract Effective Date in the FTEAM Universe

→ Discontinued collection of the Call Log tables, but will now analyze call routing and classification oversight in CPE

→ Removal of the following fields in the ECT Universe

  • Medicare Compliance Department Employee verification
  • Compliance Department Job Description
  • Compliance Committee Member verification
  • Compliance Committee Member’s Role

→ Suspension of the Website review in FA

→ Suspension of Enrollment Verification in SNP-MOC

→ Tracking Comprehensive Addiction and Recovery Act (CARA) beneficiary at-risk determinations in the SRD and ERD Universes


At the January 2019 Health Care Compliance Association (HCCA) Managed Care Conference, John Scott, Acting Director of Medicare Parts C and D Oversight and Enforcement (MOEG), spoke to the need for Plans to conduct mock audits to confirm preparedness for the upcoming audit season.   While CMS has not directed Plans on the use of external entities to perform mock audits, Mr. Scott cautioned Plans on using reputable advisors with substantial Medicare knowledge to assist them in audit preparations and validations. Preparing for an audit ahead of time by knowing you have good data, a strong team of internal and external partners, and support of your leadership will significantly help you as you go through an audit.

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