HCCA Official Site
FFM Compliance Review Best Practices
Initial Steps [pic]
➢ Advise senior leadership of Plan selection for compliance review
➢ Conduct kick-off meeting with senior team and request that they identify a single point of contact from their area to support the audit
➢ Compile and review all cited regulatory references and applicable sub-regulatory guidance for each item on the document request list (DRL)
➢ Establish standards for documentation submitted as evidence of compliance
Document Submission [pic]
➢ Establish an internal file naming convention that conforms to CMS requirements, e.g., include HIOS ID and reference to DRL # at the beginning of all file names
➢ Utilize a data repository with version controls rather than e-mail for document submission
▪ Staff uploaded files to a dedicated SharePoint site with a folder structure aligned to the DRL items
➢ Upload all documents responding to a specific item in the document request list in the same batch of files
➢ Create document guides when multiple documents will be provided as evidence of compliance for a single DRL item
➢ Create a tracking spreadsheet containing all Plan questions and auditor responses
Desk Review [pic]
➢ Conduct pre-meetings with each subject matter expert to review guidance, submitted documentation, and specific talking points including items to highlight and responses to any improvement opportunities
➢ Negotiate scope of interview with HMS auditor in advance. Seek commitment to cover a narrow range of related topics in order to ensure appropriate staff are available to respond to auditor questions
➢ Conduct team interviews on related topics to minimize post interview follow-ups
▪ Ex. Network contracting, directory team, and legal in the same interview session to address Essential Community Provider, directory, and network questions
➢ Logistics:
▪ Require in-person attendance
▪ Designate speakers for each potential concern prior to start of CMS interview
▪ Designate meeting roles such as meeting facilitator, scribe, and ‘system’ navigator
▪ Establish visual cues to seek help during interviews to avoid long pauses
▪ Use mute button on conference line and project materials being reviewed by the auditor during the sessions for ease of reference
Interview Post-Mortem [pic]
➢ Immediately recap with all participants after the interview
▪ Action items, assignments, and delivery dates
▪ What went well and what did not go well
➢ Prepare summary for distribution to leadership and meeting participants
➢ Prepare summary for CMS auditors with agreed to follow-ups and delivery dates
▪ Conduct brief alignment phone calls with audit lead to review meeting summaries
Audit Wrap-up [pic]
➢ Maintain single point of contact between Plan and auditors for all follow-up inquiries
➢ After receipt of request for follow-up establish mutually agreeable delivery dates and aim to deliver on or before scheduled date
➢ Be responsive, acknowledge receipt of each inquiry within one business day
➢ Review report and identify items that require clarification on items that you do not agree with
▪ Ex. Documentation submitted but not evaluated that contains information cited as missing
➢ Prior to exit conference, confer with impacted areas to understand whether findings have been addressed, are in progress, or not on radar
▪ These data points will help when agreeing to delivery dates for work plans
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