Tip of the Month
Audit Preparedness and Response
Are you and your staff prepared for an external audit? In today’s hospice environment, there are any number of entities that could audit your clinical records. Some are auditing for reimbursement recovery while others are auditing to ferret out fraud and abuse. No matter the reason, a hospice should have a basic process in place to deal with audit requests. Your process should include: 1. Identifying a point of contact for internal and external communications. That person should: • Ensure that staff members who open mail and answer the phone know which callers or correspondence to forward immediately. • Know the players in your geographic area— such as your Medicare Administrative Contractor (MAC); Zone Program Integrity Contractor (ZPIC); Medicaid Integrity Contractor (MIC); and Recovery Audit Contractor (RAC). 2. Establishing an internal team for audit responses (i.e., an interdisciplinary team comprised of legal, finance, clinical, compliance and IT staff). 3. Stamp all correspondence from audit contractors with the date and the time it was received. There are very specific timeframes for responding to these various auditors and the clock may already be ticking when correspondence or a call requesting information is received by the provider. 4. Develop central tracking mechanisms for all incoming and outgoing correspondence. • Track auditor requests for patient information, and implement a system and process to track what information was sent to the auditor and the dates it was sent. • Coordinate the tracking mechanisms with the communications structure—record reviews and appeal of recoupment deadlines. 5. Copy all information sent to auditors so you can easily identify and access it later should follow-up be necessary. 6. Review all information sent to auditors to determine risk and response, and engage legal services as necessary. The best strategy for audit preparedness is proactive self assessment to (1) identify potential problems and risk areas and (2) address them in your QAPI plans. For example, review your organization’s previous state and federal survey deficiency reports; the reasons for your MAC/FI claims denials; and MAC/FI ADRs. Doing so will alert you to possible trends and areas for performance improvement.
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NewsLine
Table of Contents for the Digital Edition of NewsLine - October 2011