Some organizations use the terms “monitoring reviews” and “auditing” interchangeably. However, the two activities have different meanings and expectations. CMS considers monitoring as an ongoing daily event which includes conducting analyses and tracking trends to correct issues” in real time” at the lowest level of detection. As is explained in Chapters 9 and 21, monitoring reviews occur regularly during normal operations. The staff in the department being monitored often performs the monitoring activities. Monitoring occurs on a regular basis, e.g. daily, weekly, monthly, semi-monthly, bi-monthly, etc. Monitoring is, for example, a check to see if procedures are working as intended. For example, staff might perform a check once a month or once every three months to make sure that the process for distribution of HPMS memos is being followed and is working such that all persons who should receive a particular HPMS memo is receiving it.Auditing is a formal retrospective review with a methodical approach and sampling of cases. It is performed periodically, though less often than monitoring – e.g. every 6 months or annually. Those performing audits must be independent of, and not employed in the department being audited. An audit is a more comprehensive review than is monitoring. Auditors review compliance against a set of standards, such as compliance with statutes and regulations or compliance with the sponsor’s internal requirements, used as base measures. Thus, for example, the sponsor might audit its sales department to confirm compliance with all of CMS’ agent/broker requirements. Auditors would pull a number of sample cases and review them to determine if they meet CMS sales and marketing requirements. Both monitoring and auditing activities should involve asking probing questions to the root cause of why issues are happening and further development to correct the issues at hand.
