FFM Compliance Review Best Practices

Initial Steps

 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

 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

 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

 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

 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