Documentation and Working Papers

20.5 - Documentation and Working Papers (Rev. 308, Issued: 10-26-18 Effective: 09- 01- 18, Implementation: 11-27-18) The contractor shall document through its working papers, the process it employed to support its internal control certification. This documentation shall include working papers so that a CMS reviewer can conclude that the Risk Assessment process as described in Section 20.1 follows or exceeds these guidelines, and that the Control Activities (Section 10.2.3.3) identified to support the high risk control objectives selected for review are current and clearly stated. Finally, the CPIC documentation shall demonstrate how the Testing Methods employed comply with the general parameters as described in Section 20.4 for the purpose of Control Activity validation. Working papers contain evidence accumulated throughout the review to support the work performed, the results of the review, including findings made, the judgment and/or conclusion of the reviewers. They are the records kept by the reviewer of the procedures applied, the tests performed, the information obtained, and the pertinent judgment and/or conclusions reached in the review process. Examples of working papers are review programs, analyses, memoranda, letters of confirmation and representation, abstracts of documents, and schedules or commentaries prepared or obtained by the reviewer. Working papers may be in the form of data stored on tapes, film, or other media. General Content of Working Papers - Working papers should ordinarily include documentation showing that: • The work has been adequately planned and supervised. • The review evidence obtained, the reviewing procedures applied, and the testing performed has provided sufficient, competent evidential matter to support the reviewer's judgments and/or conclusions. Format of Working Papers - Working paper requirements should ensure that the working papers follow certain standards. As a whole, a good set of working papers should contain the following: • The objectives, scope, methodology, and the results of the review. • Proper support for findings, judgments and/or conclusions, and to document the nature and scope of the work conducted. • Sufficient information so that supplementary oral explanations are not required. • Adequate indexing and cross-referencing, and summaries and lead schedules, as appropriate. • Date and signature by the preparer and reviewer. • Evidence of supervisory review of the work. • Proper heading should be given to the basic content of the working papers. End Sections 20.5 – Documentation and Working Papers and 20 – CMS Contractor Internal Control Review Process and Timeline: Back to Table of Contents