Let’s have a conversation
What Medicare Advantage Plans Need to Know
Executive Takeaways
• Service Level Data Collection becomes significantly more important
• New audit documentation and universe requirements increase year-round readiness expectations
• D-SNP coordination requirements continue to expand
Key Changes in the 2027 Program Audit Protocols
New reliance on the Service Level Data Collection for Initial Determinations and Appeals
- CMS plans to replace universe tables with the quarterly Service Level Data Collection for Initial Determinations and Appeals. Until that reporting is fully implemented and available, universe tables will continue to be used
- What this means for Health Plans: The shift from audit-specific universe table submissions to quarterly Service Level Data Collection reporting increases the importance of ongoing data integrity and positions audit readiness as a continuous, year-round activity for MAPD plans.
Redesigned, new and retired universe tables and other audit documentation
- The updated protocols enhance audit efficiency and clarity through expanded CDAG, ODAG and SNPCC universe fields, standardized root cause analysis templates, and a simplified CPE questionnaire. CMS also reduced reporting burden by removing FA Table 4 and most ODAG universes, with those data elements transitioning to the Service Level Data Collection. A new ODAG universe for reopened Part C redeterminations was also introduced
- What this means for Health Plans: Organizations that wait until audit season will struggle to meet these expanded documentation expectations. Leading plans should begin strengthening data validation, governance and audit readiness processes now.
Increased D-SNP Care Coordination Requirements
- CMS added three new compliance standards addressing integrated HRAs, Medicaid coordination assistance, and hospital/SNF admission notifications. The SNPCC universe was also enhanced with new data elements to better capture and assess D-SNP care coordination activities.
- What this means for Health Plans: For health plans, these updates reflect CMS’s increasing focus on ensuring meaningful integration and coordination between Medicare and Medicaid services for D-SNP members. Recent regulatory developments, including the Final Rule, signal heightened oversight in this area, making it critical for plans to evaluate and strengthen their D-SNP integration processes, document coordination activities, and ensure compliance with evolving Medicare-Medicaid coordination requirement
ProspHire Perspective
Although CMS reduced certain reporting requirements, these updates collectively reinforce a larger trend: CMS expects health plans to demonstrate continuous operational readiness, not simply prepare for an audit event.
Why this Matters
While several protocol updates reduce reporting burden, the brooder direction from CMS is clear: audit readiness is becoming a year-round operational capability rather than an annual compliance exercise. Organizations that invest now in stronger governance, documentation and data quality will be better positioned for future audits and evolving regulatory expectations. expectations.
Why ProspHire
We help Medicare Advantage organizations:
- Strengthen audit readiness
- Improve universe accuracy
- Build sustainable compliance processes
- Prepare for evolving CMS requirements
Talk with our Medicare Advantage experts about preparing for the 2027 audit changes.
