Surprising Outcomes of CMS Program Audits of MA Plans

Steve Bunde

Compliance Program

• Turn Around Time for Document and Sample Responses– Prepare in advance– Submission for each item requested, use Word document summary if

need– One year look back period

• First Tier, Downstream and Related Entity (FDR)– Level of expected oversight: not much attention to monitoring

activities, only selected actual ‘audits’, collect FDR’s main documents (e.g., Code of Conduct, etc.)

• CEO and Board of Directors Knowledge and Engagement– In depth expectation of CEO knowledge and engagement, Board

member understand of FWA activities

Compliance Program

• Training and Education – Provide to employees, Board, volunteers, temporary employees, new

employees– Method to determine effectiveness

• Lines of Communication – Evidence of communication of methods to report concerns – Communicating new regulatory or sub-regulatory changes (e.g., all

HPMS memo’s during audit period)

• Auditing/Monitoring Function– Expect formal Risk assessments and work plans– Sanction screening: employees, temporary employees and Board

members– Method to assess effectiveness