Challenges CMS requires both new and existing plans to perform ongoing oversight of any delegated function. Since the client had not yet conducted an audit of functions delegated to the vendors, the consultants reviewed dozens of delegated policies and procedures. Additionally, CMS requires an annual evaluation of the effectiveness of an MA plan’s compliance program. Due to a lack of internal resources, the client needed the consulting team’s assistance to review the performance of its delegates and perform the compliance program assessment. Solutions The consulting team evaluated all the operational policies of the client’s delegated entities to ensure compliance with CMS regulations. Many of the policies were outdated and contained inaccurate references to CMS regulations

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