Transition is highly scrutinized and frequently audited within the Medicare Part D program. For 2021, the Centers for Medicare & Medicaid Services (CMS) performed the Transition Requirements Analysis (TRA) to identify enrollees who were inappropriately denied a transition fill. BluePeak anticipates CMS will resume this audit in 2022. Additionally, if selected for a program audit, CMS will target up to 30 transition claim samples to perform a detailed audit on the sponsor’s transition process. For both areas, findings may result in CMS enforcement actions that include a civil money penalty (CMP), suspension of enrollment, and/or possible contract termination. Below is a list of action items that plan sponsors can take to prevent a transition finding.