The CMS 2026 Program Audit Annual Updates bring several important changes that healthcare sponsors must address to stay compliant. These updates affect various aspects of the audit process, from condition classifications to new requirements for validation audits.

At Advent, we are committed to helping organizations navigate these changes with confidence. Below, we’ve outlined the key action items from the CMS 2026 updates, along with how Advent’s services can support your compliance efforts.

1. New Condition Classifications

CMS has removed references to audit scoring and point values, introducing new condition classifications and updated corrective action processes. These changes require organizations to adapt their approach to audit findings:

• Corrective Action Required (CAR): Prepare to address findings that require correction. CMS expects Sponsor Organizations to prioritize findings that may impact access to services or result in adverse outcomes if left uncorrected.
• Observation: Monitor and document noncompliance that doesn’t require a formal corrective action plan but still needs attention.
• Invalid Data Submission (IDS): Ensure universe data submissions are accurate and complete.

Advent’s role: 

We can help you develop corrective action plans, track progress, and ensure compliance with the updated requirements. Our data management solutions also ensure accurate and complete submissions to prevent issues with IDS.

2. Prepare for the New Compliance Program Effectiveness (CPE) Audit Approach

The new Compliance Program Effectiveness (CPE) Audit approach requires in-depth discussions with CMS about how your compliance program prevents, detects, and corrects noncompliance. CMS expects organizations to demonstrate a comprehensive, proactive compliance program.

Advent’s role: 

Collaborating across compliance and program teams, we help identify root causes of noncompliance and ensure corrective actions are taken. We also assist in collecting and organizing Compliance Oversight Activities (COA) universe data for CMS review.

3. Plan for Quarterly Compliance Calls

CMS will continue hosting quarterly educational calls for compliance officers. These calls are an opportunity to learn about common compliance issues, best practices, and share knowledge with industry peers.

Advent’s role: 

We recommend assigning compliance officers to participate in these calls. Advent can also assist by helping your team stay updated on the latest CMS developments and preparing them with relevant questions or topics for discussion.

4. Understand Validation Audit Requirements

CMS’s focus on validation audits is critical, particularly for findings that require validation. Simple corrections may only require evidence of correction, such as updated templates, while complex findings may lead to independent validation audits.

Advent’s role: 

We can help track which findings require validation audits and prepare the supporting documentation needed. Our team will also help monitor the number of conditions requiring validation to determine if an independent auditor is necessary.

5. Monitor Routine Audit Updates

Be prepared for routine audit engagement letters from CMS between February and August 2026. Fieldwork periods will last for two weeks, and your organization needs to be ready to coordinate resources accordingly.

Advent’s role: 

We can help plan for the audit fieldwork, ensuring that all necessary resources are available and that compliance with Part C coverage and utilization management requirements is met.

6. Utilize CMS Resources

CMS provides helpful resources, including the User Group Resource Document, Audit Submission Checklist, and FA Validation Work Plan Training. Use these resources to stay organized and ensure you meet CMS expectations.

Advent’s role: 

We will guide you through these resources and help you address any questions or concerns you have. Additionally, we can assist in preparing for submissions and making sure your organization is audit-ready.

Advent’s Support for CMS 2026 Compliance

The changes to the CMS 2026 Program Audit requirements are significant, but with the right preparation, your organization can stay ahead of the curve. Advent’s comprehensive compliance services are designed to ensure your organization is audit-ready, from corrective action planning to data accuracy and validation.

Let us help you streamline your compliance processes, reduce audit risks, and ensure your success in meeting CMS requirements.

It’s time to start preparing for the CMS 2026 Program Audit.

Review your current compliance strategies and reach out to Advent for guidance. With our support, you can be confident that your organization will be well-positioned for success.