MARS-E Audit Services | CMS-Approved 3PAO

MARS-E (Minimum Acceptable Risk Standards for Exchanges) is the official security and privacy compliance framework established by the Centers for Medicare & Medicaid Services (CMS) for all entities involved in the operation of Affordable Care Act (ACA) Health Insurance Marketplaces and related programs.

It defines the minimum acceptable risk that CMS will tolerate when protecting sensitive data such as personally identifiable information (PII), protected health information (PHI), and federal tax information (FTI) that flows through ACA Administering Entities.

Who Must Comply with MARS-E?

State-based Marketplaces (SBMs)
State Medicaid Agencies operating eligibility systems
Federally-Facilitated Marketplace (FFM) and its contractors
Small Business Health Options Program (SHOP)
Any third-party vendors or downstream entities that create, receive, maintain, or transmit Marketplace data

MARS-E is a customized subset and extension of NIST standards:

Built on NIST SP 800-53 (moderate baseline) as the core control catalog
Incorporates additional IRS Publication 1075 requirements for federal tax information
Adds CMS-specific privacy and security overlays for ACA data
Uses the NIST Risk Management Framework (RMF) as the assessment methodology

Minimum Acceptable Risk Standards for Exchanges (MARS-E)

Achieve Full MARS-E Compliance with Confidence and Efficiency

Lazarus Alliance is a CMS-approved Third-Party Assessment Organization (3PAO) and nationally recognized leader in delivering comprehensive MARS-E (Minimum Acceptable Risk Standards for Exchanges) audit and assessment services exclusively tailored for ACA Administering Entities (AEs), including State-based Marketplaces, State Medicaid Agencies, the Federally-Facilitated Marketplace (FFM), and supporting contractors.

Our MARS-E Focused Audit and Assessment program is built on the NIST Risk Management Framework (RMF) and directly maps to the MARS-E 2.2 catalog of security and privacy controls, ensuring that every mandatory policy, procedure, and technical safeguard is thoroughly examined, tested, and documented. We go beyond simple checkbox compliance—our proactive, risk-based methodology identifies real vulnerabilities, evaluates their potential impact on protected health information (PHI) and federal tax information (FTI), and delivers actionable remediation roadmaps that strengthen your overall security posture while satisfying CMS Authority to Operate (ATO) requirements.

At the conclusion of every engagement, you receive a fully CMS-compliant third-party Security Assessment Report (SAR), complete with detailed findings, risk ratings, and a prioritized Plan of Action and Milestones (POA&M)—documentation that regulators and stakeholders trust.

What sets us apart is speed, transparency, and continuous support:

Assessments are typically completed 46% faster than traditional methods through our proprietary Continuum GRC SaaS platform
24/7 real-time access to your audit workspace, evidence repository, and live progress dashboard
Ongoing guidance from dedicated Cybervisors—former CMS and Big Four professionals who have led hundreds of successful MARS-E assessments
Integrated continuous monitoring capabilities that keep you audit-ready year-round, not just during annual cycles

Whether you’re preparing for your first CMS ATO submission, renewing an existing authorization, or seeking to elevate your security and privacy program to best-practice levels, Lazarus Alliance removes the complexity and uncertainty from MARS-E compliance.

Take the next step toward unbreakable compliance and stakeholder trust. Contact a MARS-E specialist today at +1 (888) 896-7580 or schedule your complimentary consultation to see how we can accelerate your journey to full CMS authorization.

Basic MARS-E Audit Timeline – What to Expect with Lazarus Alliance

Embarking on a MARS-E (Minimum Acceptable Risk Standards for Exchanges) audit with Lazarus Alliance means partnering with a CMS-approved Third-Party Assessment Organization (3PAO) that streamlines compliance for ACA Administering Entities through a proactive, risk-based approach grounded in the NIST Risk Management Framework (RMF). Our process emphasizes efficiency, leveraging the Continuum GRC SaaS portal for 24/7 collaboration, which typically delivers a 46% faster completion compared to traditional methods—often wrapping up the full audit in 8-12 weeks, depending on your organization's size, readiness, and scope.

Below is a high-level basic timeline outlining the key phases, deliverables, and what to expect. This is a generalized schedule based on our proven methodology; actual timelines can be customized during your initial consultation. We prioritize transparency with real-time dashboards and dedicated Cybervisor support (former CMS and Big Four experts) to keep you informed every step of the way.

Phase 1: Kickoff and Preparation (Weeks 1-2)

What Happens: We start with a complimentary discovery call to scope your engagement, review your current MARS-E 2.2 controls (from the ~325 security and privacy catalog), and align on priorities like PHI/FTI protection and CMS ATO requirements. You'll be onboarded to the Continuum GRC portal for secure evidence upload and collaboration.
Your Role: Provide initial documentation (e.g., existing System Security Plan, policies) and designate key stakeholders.
Deliverables: Customized project plan, engagement affidavit, and access to your audit workspace.
Pro Tip: Early preparation here can shave days off the overall timeline—our Cybervisors offer guidance to fill any gaps quickly.

Phase 2: Evidence Collection and Gap Analysis (Weeks 3-5)

What Happens: Using a top-down, risk-based methodology, we conduct interviews, document reviews, and preliminary testing against NIST SP 800-53 Rev 4 controls (with IRS Pub 1075 overlays). The portal enables seamless, 24/7 evidence submission and automated workflows to identify vulnerabilities and assess impacts.
Your Role: Respond to targeted requests for artifacts, participate in virtual interviews (typically 4-6 hours total), and collaborate via the dashboard for real-time feedback.
Deliverables: Interim gap report with prioritized risks, initial remediation recommendations, and a draft Plan of Action and Milestones (POA&M).
Pro Tip: This phase benefits most from the 46% time savings—expect fewer back-and-forths thanks to the portal's efficiency.

Phase 3: Testing and Validation (Weeks 6-8)

What Happens: Hands-on testing of controls across 19 families (e.g., Access Control, Incident Response, Audit & Accountability), including technical scans, configuration reviews, and simulation of threats. We validate mandatory policies, procedures, and safeguards for ACA Marketplace data.
Your Role: Facilitate access to systems (non-disruptively) and address any immediate findings during walkthroughs.
Deliverables: Detailed test results, vulnerability assessments, and updated POA&M with risk ratings.
Pro Tip: Our continuous monitoring integration starts here, setting you up for year-round compliance beyond the audit.

Phase 4: Reporting and Closure (Weeks 9-12)

What Happens: We compile everything into a CMS-compliant third-party Security Assessment Report (SAR), including executive summaries, control mappings, findings, and mitigation strategies. Final reviews ensure readiness for ATO submission.
Your Role: Review drafts and approve the final SAR for stakeholder sharing.
Deliverables: Complete SAR package, final POA&M, and post-audit debrief with actionable next steps.
Pro Tip: The SAR is designed for easy CMS submission and builds stakeholder confidence—many clients report smoother ATO approvals.

Phase	Duration	Key Focus	Efficiency Driver
Kickoff & Preparation	1-2 Weeks	Scoping & Onboarding	Cybervisor Consultations
Evidence & Gap Analysis	2-3 Weeks	Documentation Review	Continuum GRC Portal
Testing & Validation	2-3 Weeks	Control Testing	Risk-Based Prioritization
Reporting & Closure	3-4 Weeks	SAR Delivery	Automated Workflows
Total	8-12 Weeks	Full MARS-E Compliance	46% Faster Overall

Why This Timeline Works for You

Unlike rigid, drawn-out audits, Lazarus Alliance's approach minimizes disruptions while maximizing outcomes—delivering not just compliance, but a fortified security posture. Post-audit, we offer continuous monitoring to keep you ATO-ready year-round, reducing future assessment times even further.

Ready to map this to your calendar? Contact a MARS-E specialist today at +1 (888) 896-7580 or schedule your free consultation. Let's turn compliance into a competitive advantage.

What is MARS-E, and why do ACA Administering Entities need to comply?

MARS-E (Minimum Acceptable Risk Standards for Exchanges) is the CMS-mandated security and privacy framework for entities handling ACA Marketplace data, including State-based Marketplaces, Medicaid agencies, the Federally-Facilitated Marketplace (FFM), and contractors. It ensures the protection of sensitive information like PHI, PII, and FTI through NIST SP 800-53-based controls. Compliance is required annually to secure or renew your CMS Authority to Operate (ATO)—non-compliance can result in funding cuts, enforcement actions, or operational shutdowns. Lazarus Alliance's services help you meet these standards efficiently and proactively.

What specific MARS-E audit services does Lazarus Alliance provide?

As a CMS-approved Third-Party Assessment Organization (3PAO), we offer comprehensive MARS-E Focused Audits and Assessments, including risk assessments using the NIST Risk Management Framework, implementation of privacy and security controls, documentation development (e.g., System Security Plan, policies, and procedures), and continuous monitoring. Our Cybervisors™ provide expert consultations to build and maintain your program, culminating in a fully compliant third-party Security Assessment Report (SAR) and Plan of Action & Milestones (POA&M) for ATO submissions.

How does the Continuum GRC SaaS portal improve the MARS-E audit process?

The Continuum GRC portal is our proprietary, cloud-based platform that provides 24/7 secure access to your audit workspace, evidence repository, real-time dashboards, and automated workflows. It enables seamless collaboration, automated evidence collection, and live progress tracking, reducing manual back-and-forth and minimizing disruptions. Clients typically experience a 46% faster assessment completion compared to traditional methods, turning what could be a lengthy ordeal into an efficient, transparent process.

What is the typical timeline for a MARS-E audit with Lazarus Alliance?

Our streamlined, risk-based approach usually completes a full MARS-E audit in 8-12 weeks, depending on your organization's size and readiness—a 46% reduction from standard timelines. The process includes kickoff and preparation (1-2 weeks), evidence collection and gap analysis (2-3 weeks), testing and validation (2-3 weeks), and reporting/closure (3-4 weeks). We customize timelines during your initial consultation and use the Continuum GRC portal to accelerate every phase.

What deliverables will I receive from a Lazarus Alliance MARS-E engagement?

At the end of your audit, you'll receive a CMS-compliant third-party Security Assessment Report (SAR) detailing control mappings, testing results, findings, risk ratings, and remediation strategies. This is accompanied by a prioritized POA&M for ATO applications, an engagement affidavit for stakeholder sharing (e.g., sales and marketing), and optional ongoing support like updated policies or continuous monitoring reports. All deliverables are designed for easy CMS submission and to demonstrate your compliance maturity.

Who are the Cybervisors™, and what role do they play in MARS-E audits?

Cybervisors™ are our team of dedicated IT and operational audit professionals—many former CMS and Big Four experts—with deep experience across industries and organization sizes. They guide your MARS-E program from start to finish, providing hands-on consultations for documentation development, vulnerability identification, and mitigation planning. Unlike traditional audits, their continuous involvement ensures proactive compliance, avoiding "Audit Anarchy" at year-end and keeping you ATO-ready year-round.

What are the key benefits of partnering with Lazarus Alliance for MARS-E compliance?

Beyond meeting CMS requirements, our services deliver operational efficiency (46% faster audits via technology), reduced risks to PHI/PII/FTI, lower long-term compliance costs, and enhanced stakeholder trust through credible SARs. Our Proactive Cyber Security® methodology turns compliance into a strategic advantage, with continuous monitoring that minimizes vulnerabilities and supports future CMS initiatives. Clients report smoother ATO approvals, fewer findings in subsequent years, and a fortified overall security posture.

How do I get started with MARS-E audit services, and what’s the next step?

Getting started is simple: Schedule a complimentary consultation with one of our MARS-E specialists to assess your current compliance status and tailor a plan. Contact us today at +1 (888) 896-7580 or via our website form. We'll provide a customized project roadmap, including scoping, onboarding to the Continuum GRC portal, and a clear path to your ATO—ensuring minimal disruption and maximum results.

Benefits of Achieving and Maintaining MARS-E Compliance

MARS-E compliance is far more than a regulatory checkbox for ACA Administering Entities—it delivers tangible operational, financial, reputational, and strategic advantages.

Category	Specific Benefit	Real-World Impact
Regulatory & Legal	Secure or renew your CMS Authority to Operate (ATO)	Without a current ATO, your Marketplace or eligibility system can be shut down by CMS—no exceptions.
	Avoid CMS enforcement actions, fines, or corrective action plans	Non-compliance has triggered multi-million-dollar CAPs and public reprimands for several states.
	Satisfy IRS Publication 1075 requirements for Federal Tax Information (FTI)	Prevents the IRS from revoking your ability to receive FTI—critical for eligibility determinations.
Financial	Prevent loss of federal funding and grants	CMS can withhold establishment grants and ongoing funding streams if security standards are not met.
	Lower cyber insurance premiums (many carriers now require MARS-E or equivalent evidence)	Clients routinely report 15–30 % premium reductions after providing their MARS-E SAR.
	Reduce incident response and breach costs	Strong controls = fewer incidents; average healthcare breach cost in 2024–2025 exceeds $10 M (IBM).
Operational	Annual independent assessment forces continuous improvement	Turns compliance into a driver of maturity instead of a once-every-three-years fire drill.
	Streamlined evidence collection and faster future audits (with platforms like Continuum GRC)	Many Lazarus Alliance clients cut subsequent audit time by an additional 20–40 % after the first cycle.
	Built-in continuous monitoring keeps you “always audit-ready.”	Eliminates last-minute panic and resource spikes before the next annual cycle.
Risk Reduction	Systematic protection of PHI, PII, and FTI against the threats CMS and IRS care about most	Proven reduction in high-risk vulnerabilities (e.g., improper access, unencrypted FTI, weak incident response).
	Clear, prioritized POA&M with risk ratings	Leadership can make informed budget decisions instead of guessing what to fix first.
Reputation & Trust	Demonstrate to consumers, regulators, and partners that you treat their sensitive data seriously	Public trust is fragile—states with strong MARS-E programs use it as a marketing differentiator.
	Competitive advantage when partnering or bidding on federal/state contracts	Many RFPs now list MARS-E compliance or a current ATO as a prerequisite.
Strategic	Positions your organization for future CMS initiatives (e.g., enhanced direct enrollment, new programs)	CMS routinely raises the bar—organizations already at MARS-E 2.2 are ready for the next evolution.
	Aligns you with NIST standards used by FedRAMP, CMMC, and most federal agencies	One investment in maturity serves multiple compliance needs.

Bottom-Line Summary

MARS-E compliance is the price of admission to operate an ACA Marketplace or eligibility system—but when done right (proactively and continuously), it becomes a genuine risk-reduction and value-creation engine rather than a cost center.

Organizations that treat MARS-E as a strategic program instead of a once-a-year burden consistently report:

Fewer findings year-over-year
Faster CMS ATO approvals
Lower total cost of compliance
Stronger overall cybersecurity and privacy posture

Ready to turn MARS-E compliance into a competitive advantage? Contact a Lazarus Alliance MARS-E specialist at +1 (888) 896-7580 or schedule your no-obligation consultation today.

MARS-E Compliance Audit Services by Lazarus Alliance. Call +1 (888) 896-7580 today!