For compliance departments, the need to meet Compliance Program Effectiveness (CPE) requirements is always top of mind this time of year. CMS requires that Medicare health plans conduct a CPE audit at least once annually. Failure to do so often hurts plans during the CMS audit process and can result in civil monetary penalties (CMP). Many compliance departments struggle to reap the full value such audits can provide. With the right strategy, CPE audits could deliver significant value to organizations.
Developing a strategy to get full value out of the CMS annual CPE requirement
Planning is essential to having a fruitful CPE audit. Too often established compliance departments rely on past success, confident that they know every aspect of their program and that an audit will uncover no issues. In reality, operations teams often make changes of which compliance teams are not aware. These changes can impact adherence to regulatory requirements. In addition, CMS requirement changes can also easily slip under compliance teams’ radars. Strong performance in the past does not guarantee success. To be successful, focus on finding the right CPE strategy, which can also help improve the overall compliance program effectiveness.
Having a multi-year strategy is best because it helps compliance departments be better prepared, which frees them to be more strategic. For example, a multi-year strategy can help compliance programs avoid doing a complete audit every year, allowing them to pursue instead different types of action programs, which can be more tailored.
A vital tip for compliance programs to remember is not to look at CPEs in isolation. There are numerous audit options, and exploring those options is key to determining which the program needs.
Considering options for the CMS annual CPE requirement
Where a compliance department is in the program audit cycle is an integral part of determining which strategy is best. Identifying the type of audit that the department needs will help a compliance department function at a higher level.
Here are four strategies for meeting CPE requirements while performing audits that add value:
Working with a Consultant to Evaluate Compliance Program Effectiveness
Having an independent audit is critical for meeting CPE requirements, but there are multiple ways to do so. Organizations can conduct internal audits on themselves as long as it’s an independent audit, meaning outside the compliance department and removed from specific activities they’ll be reviewing. While it isn’t necessary to use an outside firm, there are many benefits to working with one, including:
Meet 2019 CPE requirements
However you choose to meet your CPE requirement, it’s important to stop looking at CPE as a checkbox and start seeing it as an opportunity to improve your compliance program’s effectiveness. We believe every organization can get value from an audit, beyond simply meeting the regulatory requirement.
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