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