Return Mail and CMS Audits: What You Don’t Track Can Hurt You

Originally published by Command Direct

When it comes to CMS compliance, health plans are expected to have complete control over their member communications. That includes everything from ID cards and Annual Notices of Change (ANOCs) to benefit explanations and regulatory mailings.

So, what happens when that mail is returned undelivered?

In the eyes of regulators, that’s a red flag. And if your team isn’t tracking return mail—or doesn’t have a clear process to resolve it—you could be exposing your organization to serious audit risk.

CMS Is Paying Attention?

CMS requires health plans to make a good faith effort to ensure members receive required documents. This includes confirming address accuracy, documenting delivery attempts, and managing undeliverable communications.

Returned mail without a resolution process can trigger issues in multiple areas:

• Enrollment validation – Returned ID cards or welcome kits may raise concerns about active enrollment

• Communication compliance – Undelivered ANOCs or LIS notices can result in citations

• Audit readiness – Lack of tracking or remediation may signal non-compliance

The more volume you handle, the bigger the risk if you’re not managing return mail strategically.

Documentation Is Your Defense

If CMS auditors ask for records related to returned communications, will your team be ready?

Plans should be able to:

• Show logs of returned items

• Document how returned mail is processed and resolved

• Demonstrate re-mailing or outreach efforts

• Prove that PHI was handled securely in every step

Without a documented Return Mail Management process, most teams can’t confidently check those boxes.

A Built-In Compliance Layer

Command Direct’s Return Mail Management solution is designed with CMS and HIPAA compliance in mind.

We help health plans:

• Track and process return mail securely

• Maintain audit trails

• Safely manage PHI across all touchpoints

• Integrate address cleansing and re-mailing into your operations

We take the burden off your internal teams—so you can stay focused on member care and regulatory excellence.

Final Thoughts

If return mail is piling up without a plan, it’s time to act. CMS won’t overlook it, and neither should you

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> READ THE ORIGINAL POST