More rigorous requirements for conducting the CMS Audit Validation and Close Out are posing new challenges for health plans facing scheduled CMS Program Audits in 2019 and beyond. It’s critical that compliance staff understand how the new CMS Audit Validation and Close Out process works and plan for it well in advance to ensure a successful outcome.
The Audit Validation and Close Out process is the final phase of a scheduled CMS Program Audit. The goal is to ensure that the sponsoring health plan substantially corrects all non-compliant findings and conditions that were found during the initial CMS Program Audit. CMS reviews the results of the Validation Audit to determine whether it can officially close the sponsoring health plan’s Program Audit.
In 2018 CMS clarified the requirements for how health plans must perform the Validation Audit. For sponsoring health plans that have scheduled audits occurring this year and beyond, this will be the first time they will be subject to this more structured and rigorous process:
Sponsoring plans must now provide greater levels of documentation and a consistent number of case file reviews than previously required. This not only increases work levels for the plans – it also exposes them to greater levels of risk. That’s because the greater the number of files reviewed, the greater the risk for human error in one of those files selected.
Based on The Burchfield Group’s experience in this realm, here are 8 best practices for health plans worried about how to meet the new Audit Validation Requirements:
The validation audit is an important step in closing out the CMS program audit cycle. Remember to begin your search for an independent auditor even before CMS completes its portion of the program audit.With the right preparation and support your health plan can complete this efficiently and become stronger in your overall CMS compliance efforts.
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