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CMS Program Audit – CMS Program Universe Validation Service

Advent Advisory Group is a recognized leader in helping organizations prepare for the CMS Program Audit with special focus on data integrity and universe submission validation.  Advent’s CMS Program Universe Validation services allow for customizable levels of support which include evaluation of the quality, accuracy, and completeness of each program universe.  We work with our clients to ensure that program universes are valid, accurately extracted, and most importantly, comply with CMS guidance and protocols.

CMS Program Audit - CMS Program Universe Validation Service

Are you ready for a CMS Program Audit?

CMS program audits are intended to  measure a sponsoring organizations–Medicare Advantage Organizations (MAOs), Prescription Drug Plans (PDPs), and Medicare-Medicaid Plans (MMPs) compliance with all Medicare Parts C and D program requirements. Generally, plans are required to undergo CMS program audits on average every three to four years. Once plans have been notified of an upcoming CMS program audit, the turnaround time is a very short 15 days. Understanding the universe submission requirements and producing universes that meet CMS requirements is a critical component in success. Additionally, CMS recently released updated specifications for the universes.

CMS program audits cover the following areas:

  • Compliance Program Effectiveness (CPE)
  • Part D Formulary and Benefit Administration (FA)
  • Part D Coverage Determinations, Appeals and Grievances (CDAG)
  • Part C Organization Determinations, Appeals, and Grievances (ODAG)
  • Special Needs Plans Care Coordination (SNPCC)
  • Medicare- Medicaid (MMP) service Authorization Requests, Appeals and Grievance (MMP- SARAG)
  • Medicare-Medicaid Plan (MMP) Care Coordination and Quality Improvement Program Effectiveness (MMP- CCQIPE)

The most recent technical notes regarding the upcoming CY 2020 cycle indicate that MAOs that have not had a CMS program audit in the past two years are most likely to be identified for potential audit in the near future. CMS protocols indicate that plans notified of a program audits have 15 business days to provide accurate universe submissions as the first step in the process. Confirming that your organization has the ability to produce CMS-ready universes is critical. Failure to provide accurate universes after three attempts results in a CMS program audit finding of “Invalid Data Submission” or IDS. Partnering with Advent to have your CMS universes tested will provide your organization with invaluable information to your business owners and your compliance teams. Our process will help identify anomalies, perform timeliness testing, and most importantly, avoid potential data issues that can result in a CMS Audit Finding.

Advent’s team is staffed with experienced auditors with over twenty-five years’ experience in Medicare compliance and reporting.  Advent has developed proprietary tools for each of the program audit areas to identify any non-compliance at the record level. Advent’s CMS Universe Validation services assist organizations in assessing the quality, completeness, and integrity of each program audit universe under scope. Advent services are customizable to allow for the level of review that addresses your organization needs.


For more information on Advent’s CMS Universe Data Validation services,  contact