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Medicare audits: CMS imposes Corrective Action Plans on sponsor faults.

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Beginning on October 1, 2007, the Centers for Medicare and Medicaid Services (CMS) began posting what are called Corrective Action Plans (CAP) on the public area of its Web site. The intent of this was to allow public viewing of review findings from audits conducted on Medicare Advantage (MA) and Part D plans from January 1, 2006, through September 30, 2007, that resulted in a CAP. This practice has continued since October 2007 with newly posted CAP information as of June 2008.

As the MA and Part D programs have progressed and their fiscal costs have grown exponentially, Congress and other oversight agencies such as the Office of Inspector General (OIG) and the Government Accountability Office (GAO) have placed increasing pressure on CMS to be more proactive in its scrutiny of plan sponsors to ensure compliance with regulations. With this pressure came the decision to take the CAPs out of the vacuum and expose them publicly.

A CAP is a program imposed by CMS that results from findings of deficiencies from an MA and/or Part D audit conducted by CMS or one of its contracted audit entities. The CAP requires the plan sponsor to take affirmative steps to rectify specific deficiencies identified. CMS conducts biennial audits of its contracted plan sponsors to ensure that MA and Part D programs are complying with regulations and that there are adequate safeguards in place to provide assurance that the program is being administered appropriately. CMS utilizes audit guides to review an MA or Part D plan sponsor's compliance with...

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