Medicare Independent Auditor Validation

Medicare Part C and D Independent Auditor Validation

Attest offers IA Validation services to Medicare Advantage and Prescription Drug Plans to validate that any issues identified during a CMS program audit have been rectified. Attest will validate that all sanction and non-sanction related conditions have been corrected..

On February 12, 2015, CMS issued CMS-4159-F2 (See 80 FR 7912–7966) which finalized changes to 42 CFR 422.503(d) (2) and 423.504(d) (2). In that final rule, CMS has the authority to require a sponsoring organization (hereinafter referred to as the Sponsor) to hire an IA to validate if the deficiencies that were found during a CMS full or partial program audit have been corrected. For all program audits from 2015 onward, CMS will notify the plan if an IA is required.

CMS has stated that the IA firm must meet the following requirements:
-- The Sponsor must attest that the IA is independent with no conflicts of interest. The IA may not be a first-tier, downstream or related entity.
-- The auditor must have subject matter expertise in the areas of Medicare Part C & D that will be subject to review.

Attest will work with you to develop a work plan and timeline that meets plan and CMS expectations. Because each validation will be unique based on your program audit results we will work together to identify tasks and timeframes. We will collaborate with you to determine if sampling or validation of the entire universe is prudent. Once this plan is developed Attest will meet with CMS and the Sponsor to walk through the documentation regarding the validation and then finalize it for CMS approval.

Attest will then execute the plan and draft a report for the Sponsor to review. It will provide outcomes of the testing but per CMS guidelines will not determine whether or not individual deficiencies have been remedied. The Sponsor may discuss any disagreements or responses to the report. After the Sponsor believes corrections have been made to address the issues the Sponsor will attest within HPMS that these issues have been corrected and submit the IA's report.

CMS will then review the report submitted by the Sponsor and if necessary seek clarification on the documentation submitted. CMS will then schedule a call with the Sponsor's CEO and Medicare Compliance Officer to provide them CMS's determination and next steps if needed.

For questions regarding the IA validation process, plans should email

Complete guidelines and descriptions of the process may be found here: CMS

Medicare Data Validation Audits performed by Attest do not present a conflict of interest to performing IA work.

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