Now’s the Time: Complete Your Annual Compliance Program Effectiveness Audit Before Year-End

As we enter the second half of the year, it’s time to prioritize one of CMS’ most important requirements for Medicare Advantage and Part D sponsors: the annual Compliance Program Effectiveness (CPE) audit.

Plans are expected to conduct a meaningful, documented review of their compliance program at least annually. This includes evaluating the design and operational effectiveness of your compliance framework—and ensuring your oversight extends to any delegated entities.

But here’s the challenge: many organizations put off this requirement until Q4, only to find themselves up against tight internal timelines and holiday staffing constraints.

Why Now?

Scheduling and completing your CPE audit before November avoids year-end backlogs and gives your compliance team time to respond to any findings in a thoughtful, measured way. Key findings and Observations from the CPE Audit will also help inform your organization’s 2026 Risk Assessment and Audit Workplan.

Structured Yet Flexible: 3 or 6 Sample Tracers

We work with clients to design a CPE audit that is both rigorous and achievable. CMS guidelines allow for flexibility in the tracer methodology—meaning you can choose to audit:

• 3 operational samples (minimum for low-risk programs), or

• 6 samples (for broader program evaluation or higher-risk areas)

The audit includes a review of how compliance is integrated into areas like:

• First-tier, downstream, and related entities (FDR) oversight

• Monitoring and auditing protocols

• Training and education

• Incident reporting and corrective actions

• Policies, procedures, and governance

What You Get

Partnering with us means:

• An objective, third-party review of your compliance program’s strengths and vulnerabilities

• Actionable recommendations that align with CMS expectations

• Documentation you can use to satisfy internal, external, or regulatory requests

• Support for delegated entities, including evaluating downstream oversight

Let’s Get You on the Calendar

Our availability fills up quickly in Q4, so we encourage clients to begin their audits in Q3 or early fall. Completing your audit before the holidays ensures a smoother process, with time to course-correct and show leadership you're ahead of regulatory expectations.

Ready to schedule your CPE audit? We’ll help you tailor the scope, structure your tracers, and complete your audit efficiently—before the year wraps up. Let’s talk today.

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