December 1, 2022

CMS issues 2023 Program Audit Protocol Updates

On November 30, 2022, the Centers for Medicare & Medicaid Services (CMS) released a memo on the 2023 Program Audit Updates, which include 6 points of emphasis:

1. CMS will continue to use the 2022 Final Audit Protocols for the Medicare Part C and Part D Program Audits and Industry-Wide Part C Timeliness Monitoring Project (CMS-10717) and the 2022 MMP Audit Protocols and Data Requests to conduct 2023 program audits. The 2022 Protocol and supplemental information can be found 2023 Program Audit Process Overview (

2. CMS may use flexibility when conducting audits, which includes their ability to review related requirements not specially addressed in the protocols.

Example: Beginning in 2023, CMS will inquire, when applicable, how Sponsoring organizations who offer a D-SNP implemented these requirements in an effort to understand how D-SNP enrollees are provided the assistance prescribed in the CMS final rule (CMS-4185-F) published April 5, 2019.

3. CMS will continue exploring opportunities to respond to stakeholder feedback received on the program audit process and implement improvements and efficiencies.

4. Delivery of program audit engagement letters to Sponsoring organizations beginning February 2023 through July 2023.

5. CMS will notify Sponsoring organizations in the audit engagement letter whether the compliance program effectiveness portion of the audit will be conducted onsite at the Sponsoring organization’s location.

6. CMS clarified standard impact analysis data collection timeframe is 10 business days from request.

Medicare Advantage (MA) Sponsors should ensure their compliance and operations teams are aware of the changes included in the 2023 Program Audit Process Overview.

Learn more about BluePeak’s audit support. Contact BluePeak today for common findings and best practices from the 2022 Program Audit season and reserve BluePeak resources in the event you receive an audit notice.

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