Given COVID, 2020 Program Audits Were Light on Findings

Due to the unique constraints of the COVID-19 pandemic, CMS in the newly released 2020 audit report revealed that it audited only six plan sponsors, representing just 1.4% of all Medicare Parts C and D enrollment. Given the small sample size and the flexibilities that CMS granted plan sponsors during the public health emergency (PHE), the latest annual report does not provide many useful takeaways. However, increasing fines related to so-called “one-third financial audits” — which are separate from program audits — do offer some lessons learned for Medicare Advantage organizations, says one industry expert.

In the 2020 Part C and Part D Program Audit and Enforcement Report issued May 14, CMS reminded readers that it adjusted its 2020 audit strategy due to the PHE and cautioned “against drawing conclusions about the overall performance of audited sponsors in 2020 compared to those that were audited in previous years.” CMS last March put scheduled program audits on hold so that the agency and plan sponsors could focus more directly on the pandemic, but it picked them back up again in the fall.

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