Tips for CPE Audit Tracer Evaluations

CPE Audit Tracer Presentations continue to be a hot button for plan sponsors.  CMS auditors frequently find compliance and operational deficiencies through the tracer process. Since the Compliance Officer is responsible for the management of tracer presentations, it is crucial that the Compliance Program employs strict protocols for the development of the tracer presentations and supporting documentation. Here are some DOs and DON’Ts for the creation and the demonstration of tracer presentations:Going through a CPE audit? CODY can help.

Presentation Template


  • Follow the CMS presentation template (included in the CPE audit universe layouts) as closely as possible.
  • Stick to the facts.
  • Use clear, concise, unambiguous language.
  • Use the same documentation for each presentation.


  • Try to be inventive or creative with the presentation. Auditors are looking for facts not words with sparkles flying across the page.
  • Use unclear or ambiguous statements or timelines. Auditors will think that the presenter is not prepared or is being intentionally misleading. They will hunt for issues.

Chronological Timeline


  • Prepare only one timeline of events for each tracer presentation.
  • Ensure that you have evidence to support the dates and events in the timeline.
  • Ensure that dates in the presentation sync with dates found in supporting documentation. This could include member or provider notices, emails, logs, reports and dates found in data systems such as call center systems, grievance and appeal systems, and incident management systems.
  • Review the tracer presentation timeline against the Pre-Audit Issue Summary and in disclosed issue reports previously submitted to CMS for the audit period. It is crucial that these align.


  • Present multiple timelines. When we see these, they often do not sync. If there are differences in the chronology and events, then auditors will question those discrepancies.

Root Cause Analysis

Root Cause Analysis can be the most frustrating element of the tracer presentation.


  • Be specific. What caused the problem? Was it a human error, a systems error, a policy or procedure error, or a combination of factors?
  • Demonstrate every element that caused the problem. It is not enough to tell an auditor that an issue was caused by an oversight in a report.
    • Example: An issue was caused by an analyst who entered the wrong data in a report. The auditors will want to know the name, job title, and responsibilities of the analyst. They will want to see the data error in the report and will want to know why the error was made. Did the analyst fail to follow a prescribed policy and procedure? The auditors will want to see any governing policy or procedure in effect at the time the issue occurred.


  • Generalize or omit details. The auditors are not only looking into what happened but asking you to identify the how and the why – i.e., the root cause.

Compliance Program Documentation


  • Have the required compliance documents for each person involved in each tracer issue ready to present to the auditors.
  • Place the documents in a folder on a desk top by name of person. These folders include the exclusion checks, compliance training certifications and code of conduct attestations. They also, can include other documents such as the conflict of interest attestation. Auditors will check these documents against the timing requirements provided in Chapter 21 of the MMCM.


  • Appear disorganized of unprepared by struggling to find the required documentation when asked for it.

Compliance Review and Practice


  • The Compliance Officer or a designee must review all the tracer presentations before sending them to CMS.
  • Create a checklist of every element that needs to be in each presentation.
  • Cross-reference the timing of events presented in the tracers to supporting documentation.
  • Practice, practice, practice. It is natural to be nervous when presenting to auditors. Practicing will help calm those nerves and hone the presentation. (Best Practice: Employ an outside firm to conduct the annual CPE audit. This will give your organization the opportunity to practice before CMS conducts a full program audit.)


  • Panic. You got this. If you follow these tips and polish your delivery with practice sessions before giving the actual presentation, you will have a successful CPE Audit Tracer Presentation.


Compliance review of tracer presentations and supporting material is crucial to success of the tracer demonstration. The event chronology in the single timeline must sync to supporting documentation dates. The root cause analysis must address every component that contributed to the issue. If your plan needs help getting through a CPE Audit Tracer Evaluation, CODY can help. We have the team, insight and expertise to ensure you achieve compliance success. For more information, contact us today.