CMS Audits – Be Prepared to Avoid These Common Findings

As the 2022 Program Audit Cycle winds up with the last of the routine audit engagement letters issued in July, we are starting to see the audit results. This year saw new audit protocols, and some plans struggled with the new universe layouts. In addition, CMS added a new observation classification – ORCAs (Observation Requiring…

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How to Avoid FDR Oversight Issues in a CMS CPE Audit

First Tier, Downstream or Related Entity (FDR) Oversight continues to be a hot topic for the Centers for Medicare and Medicaid Services (CMS) and plan sponsors. CMS auditors annually find deficiencies in FDR oversight and monitoring activities in program audits, with poor oversight of FDRs trending as a common condition in yearly audits. Many plan…

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