April 7, 2025
Advent recently hosted a webinar focused on helping Medicare plans prepare for a CMS Program Audit. With critical updates shared by our experts, our goal was to ensure organizations feel confident heading into the audit season. Here are five key takeaways you need to know: 1. CMS Engagement Letters Sent Between April and July 2025 Health plans selected for a CMS Program Audit will receive their engagement letters between April and July 2025. If you make it to August or September without receiving a letter, you're likely in the clear for this cycle. But preparation shouldn’t begin when the letter arrives—readiness starts now. Pro Tip: Advent offers pre-audit support, including mock engagement reviews and universe readiness assessments to get ahead of the curve. We also offer a self-service universe scrubber for validation of internal and/or vendor universes. 2. CMS Fieldwork is Now Condensed into a Two-Week Period CMS has consolidated fieldwork into a structured two-week window: Week 1: Review of operational program areas Week 2: Compliance Program Effectiveness (CPE) review This change emphasizes the need for timely, organized, and well-documented case files, grievance records, call notes, and communications. How Advent Helps: Our mock audits mimic this structure, helping plans prepare under realistic timelines and expectations. 3. Universe Submission Requires Speed and Accuracy After receiving the audit letter, organizations have just 15 business days to submit their universe tables. Within five days of the universe submission, CMS will conduct integrity testing by reviewing samples from each submitted table to ensure data validity and consistency. Errors in inter-field logic, case documentation, or data integrity can lead to findings. Advent’s Advantage: Our CMS Program Audit Universe Assessment scrubs your universes across ODAG, CDAG, CPE, SNP, MMPCC, FA, SARAG, and UM—highlighting issues before CMS finds them. 4. Some Tables Are Suspended for 2025—But Not Retired CMS has suspended data collection for the following tables: FA Table 3: Prescription Drug Event (PDE) CDAG Table 7: Comprehensive Addiction and Recovery Act (CARA) At-Risk Determination (AR) ODAG Table 6: Dual Special Needs Plan – Applicable Integrated Plan Reductions, Suspensions, and Terminations (AIP) Pro Tip: While not retired, these tables are on hold for this cycle. It's essential to maintain internal tracking and audit processes, as they could return in future cycles. 5. A New Audit Protocol for Part C Utilization Management Begins in 2026 Starting in 2026, CMS will implement a new audit protocol focused on Part C Utilization Management. Plans will need to: Report internal coverage criteria for CMS targeted services Identify entities or vendors involved in developing internal criteria Provide links to coverage policies Submit an annual data report by January 31 each year This new reporting requirement underscores CMS’ emphasis on transparency, consistency, and accountability in clinical decision-making. Advent Insight: We guide plans in preparing for this shift—reviewing internal policies, developing data collection frameworks, and ensuring compliance. Advent will have a universe scrubber to align with new UM protocols once finalized by CMS.