Vital Signs: September 2012
We are no longer operating in a world of “if we get
audited,” but rather “when we get audited.” Your
practice can successfully survive an audit with preparation, education,
and a well-outlined internal plan.
Recently, the North Carolina Medical Society released a YouTube video
highlighting inefficiencies in the audit process and the dangers of not
being prepared or not understanding a practice’s role in billing
audits.
While viewing the video, I found myself cringing because the featured
practice was assessed a $1 million fine by CMS. The practice then spent
over four years and $300,000 fighting the audit findings.
I often consult with MMS members about proper compliance techniques.
In speaking with practices, I routinely encourage them to prepare in
advance for audits rather than simply waiting for the day when a letter
arrives from a health plan requesting medical records. Education,
understanding, and proper planning can save your practice significant
time and money.
- Educate yourself.Know what each health plan
requires as part of its integrity program or claims review process.
Information can be found on health plan websites or by reading your
contracts.
Understand what the time period is for records review, whether or not an
auditor is allowed to visit the practice site, and the frequency with
which auditing can occur for each plan. - Know where you are at risk.Improper documentation
or processes that do not support billing levels are often the source of
error or risk. Consider engaging an external auditor on an annual basis
to perform a mock audit and discuss the findings with your practice.
Don’t forget to involve key staff in the mock audit. Consider it a
test run for the day you receive a letter from a health plan requesting
records. Use this as an opportunity to outline the internal process your
practice will take.
- Identify a designated staff member to manage the
process. It is important to have a designated full-time person
responsible for managing an audit. Do not have a temporary staff member
make photocopies of charts and drop them in the mail. That person may
not be familiar with what the audit is looking for and may not be
familiar with how the physicians in the practice document their
charts.
Choose someone familiar with the practice, how the physicians work, and
where things are located within the chart. This person will be able to
see if something important is missing or highlight the location of key
information for the audit reviewer. - Organize the information and flag important pieces for the
auditors.Practices that take this step often have high levels
of success. If things are hard to find, the auditor may miss them. In
most cases, the auditor is not on site and you will not have an
opportunity to point out where pertinent information is located.
- Make copies of submission materials.Make copies of
everything you submit, so if something accidentally goes missing,
it’s easy to provide to the auditor. Also, if your practice
questions or disputes an audit finding, knowing exactly what records
were sent will help speed response time.
— Kerry Ann Hayon
For more information on the auditing process, visit: www.massmed.org/audits.
