Ongoing Auditing and Monitoring
Navitus performs regular risk assessments, including an assessment of activities delegated to FDRs, which are used to guide the work and activities of the Compliance Program and to develop an annual audit plan. Navitus’ monitoring activities are structured to regularly review normal operations and to confirm ongoing compliance using metrics and key performance indicators. Navitus also monitors federal lists to identify providers, pharmacies, and other individuals and entities that are excluded from participation in federal programs.
As an FDR that contracts with Navitus to provide Medicare-related administrative and healthcare services, you must ensure that compliance is maintained by your organization as well as your downstream and related entities. To ensure ongoing compliance, Navitus conducts random audits, which involve requesting evidence of your compliance with these requirements including:
- Documentation that your organization’s Code of Conduct (or the Navitus Code of Conduct) and compliance policies were distributed within 90 days of hire, when there are updates, and annually thereafter;
- Evidence of completion of compliance and FWA training for employees within 90 days of hire and annually thereafter. Copies of the training materials will also be requested unless the free training from the CMS MLN website is utilized;
- Documentation showing OIG and GSA/SAM exclusion reviews were conducted prior to hire and monthly thereafter;
- Documentation of annual audits of any offshore subcontractors.
Please be familiar with these audit requirements and be prepared to produce the necessary documentation should it be requested by Navitus or CMS.