At its Medicare Advantage & Part D National Conference in April 2009, and ensuing months, CMS has broadcast its shifting audit strategy, away from routine audits towards more targeted, data-driven and risk-based audits. In connection with this change, CMS has released a consolidated Parts C and D “universal audit guide.”

In its proposed collection and comment request published in the Federal Register on Friday, July 31, 2009, CMS announced the merger of the existing Part C and Part D audit guides into a single Medicare Part C and Part D Universal Audit Guide. Currently available in draft form, the universal audit guide reflects streamlined data elements, uniform language, and omits duplicative data elements as well as previously deleted items. The information collection and comment request also includes a draft audit confirmation letter; minimum documentation requirements for sample case files; and the accompanying “universe request” for data for Medicare Advantage and Part D Plan audits. According to the document, the “universe request” is the document by which CMS seeks “the complete list of all Medicare beneficiary transactions [relating to an issue] that took place in the audit period from which CMS will randomly choose “cases” to audit for compliance.’’

Comments on the universal audit guide and accompanying documentation are due to CMS by Tuesday, September 29, 2009.