CMS Pub. 100-06, ch. 8, § 80.2

The second general standard for government auditing is:

"In all matters relating to the audit work, the audit organization and the individual

auditors, whether government or public, should be free from personal and external

impairments to independence, should be organizationally independent, and should

maintain an independent attitude and appearance."

Maintain independence so that opinions, conclusions, judgments, and recommendations

are impartial and viewed as impartial by knowledgeable third parties.

Consider the three general classes of impairments to independence:

• Personal – There are circumstances in which auditors are not impartial or are not

perceived to be impartial.

• External – Factors external to the contractor may restrict the audit or interfere

with an auditor's ability to form independent and objective opinions and

conclusions.

• Organizational – A government auditors' independence is affected by their place

within the structure of the government entity to which they are assigned and also

by whether they are auditing internally or auditing other entities. Since the

contractor audits outside the government entity to which it is assigned (i.e., CMS

is not related to the providers being audited), this is generally not a concern for a

Medicare audit, unless you are an insurance company that in its private line of

business makes payment for health care benefits to providers of service that are

related to or are based on Medicare payment formulas or payment methods.

Establish policies and procedures to provide reasonable assurance that all Medicare audit

and payment professional staff maintains their independence so as not to impair, or

appear to impair, your independence in carrying out its Medicare audit responsibilities.

See Exhibit IX in §170 of this chapter for a sample of the Personal Impairment Statement

to be completed by each individual involved in the desk review, field audit, and

settlement activities to ensure that he/she is free of personal impairments. This statement

can be completed by each individual on an annual basis and be updated during the year if

circumstances that need to be disclosed arise.