CMS Audit Support & Mock Audits: Preparing for CMS’ 2026 Pilot Audit Expectations

CMS is signaling a new era of audit scrutiny. With the introduction of its 2026 pilot audit approach, CMS is recalibrating how it evaluates Compliance Program Effectiveness (CPE)—placing heightened emphasis on real-time operational integration, governance, and issue resolution rather than static documentation alone.

This shift raises a critical question:

Can your organization clearly demonstrate how compliance prevents, detects and corrects noncompliance across day-to-day operations?

What’s Changing Under the 2026 CMS Pilot Audit Model

CMS’ evolving audit posture reflects increased expectations that compliance programs:

• Are actively embedded within operational workflows

• Maintain consistent awareness and acknowledgment of noncompliance across departments and up through leadership

• Link identified issues to meaningful, timely corrective actions

• Surface systemic or recurring issues through robust monitoring and governance

CMS reviewers are increasingly evaluating how compliance functions—not just whether required elements exist.

How Rebellis Helps Plans Meet CMS’ New Expectations

Rebellis delivers executive-level CMS audit support and mock audits designed to mirror CMS’ 2026 pilot methodology. Our experienced consultants—former compliance leaders and operational subject matter experts—help plans assess readiness through the same lens CMS will use.

Our support focuses on four critical areas:

1. Compliance and Operational Integration

We evaluate how compliance is embedded across operational areas, including whether:

• Frontline teams consistently recognize and acknowledge noncompliance

• Compliance guidance is understood, applied, and reinforced in practice

• Operational leaders demonstrate ownership of compliance risks

Solution: Rebellis identifies gaps between policy and practice and provides actionable recommendations to strengthen real-time compliance engagement.

2. Issue Management and Corrective Action Alignment

CMS expects clear linkage between:

• Identified noncompliance

• Root cause analysis

• Open or closed corrective action plans (CAPs)

Rebellis assesses whether CAPs are appropriately scoped, timely, and effective—and whether recurring or systemic issues are being escalated and addressed.

Solution: Our consultants help refine issue classification, root cause methodologies, and CAP documentation to withstand CMS scrutiny.

3. Monitoring, Auditing, and Universe Integrity

We conduct in-depth reviews of:

• Operational monitoring activities

• Internal audit results

• Conditions of Audit (COA) universes

• Operational universe tables

CMS increasingly expects these artifacts to be accurate, consistent, and defensible across departments and reporting periods.

Solution: Rebellis validates universe completeness, alignment, and traceability to ensure issues are identified, reported, and resolved consistently.

4. Communication, Escalation, and Governance

Effective compliance programs rely on strong governance. We assess:

• Communication pathways between compliance and operations

• Escalation protocols for significant or systemic issues

• Leadership and committee oversight structures

CMS is looking for evidence of transparency, accountability, and consistent messaging from frontline staff through senior leadership.

Solution: Rebellis helps plans strengthen governance frameworks and documentation to clearly demonstrate effective oversight.

Preparing Now Is Critical

CMS is looking for evidence that compliance is embedded—not siloed. Rebellis helps plans tell that story clearly, credibly, and confidently. Plans that wait risk being unprepared to demonstrate compliance effectiveness in the way CMS now expects.

Rebellis partners with health plans to transform audit readiness into a strategic advantage, helping organizations move from reactive compliance to proactive, operationally integrated oversight.

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