In the Federal Register in 2000, the Office of Inspector General (OIG) Compliance Program for Individual and Small Group Physician Practices identified monitoring and auditing as one of the seven components that provide a solid basis for an effective compliance plan. And with an increase in regulatory and payer audit activity seeking to identify improper payments, it's wise for proactive physician practices to implement processes that will ensure proper compliance.
"Many practices have programs in place to conduct medical record audits. Auditing programs come in many shapes and sizes; some utilize internal staff and others contract with an outside independent company. Some even combine internal and external reviews to provide a more robust program," explained Charla Prillaman, southeast regional director at APPC Physician Services. Prillaman has more than 25 years experience providing coding, compliance and billing services to physician practices.
"There are many ways to present audit findings. All include a 'score' or a measurement of accuracy, but the effective compliance plan does not stop at assigning a score," continued Prillaman. "Analyze the details that support the findings to ensure that potential vulnerabilities are addressed and gaps closed. The goal is more accuracy."
Prillaman shared five steps auditors can use to avoid any potential disconnect.
1. Keep your attitude and approach in check.
A rushed auditor won't communicate effectiveness and will similarly not generate any confidence.
2. Schedule your time wisely.
Most commonly, practices begin auditing activities using Evaluation and Management (E/M) medical codes as the sample selection criteria. E/M coding takes time and does not always translate into the provider’s clinical perspective. Adequate time to share your information and hear questions is key.
3. Be prepared.
Nothing will lose respect more quickly than using an illustration that is not relevant to the provider (i.e., do not use cardiology examples when talking to an orthopedic surgeon).
4. Open your ears.
Often an audit reveals information that a provider has never considered, especially when it comes to an introduction to medical coding. Be patient and listen to concerns.
5. Summarize with action points.
Close your auditing meeting by summarizing the findings with specific clear action points the provider can implement to improve accuracy. If possible, keep the instruction to two or three main points. Address compliance risk areas first and refine “perfection” later. Too much information at once can be confusing and will certainly cause resistance.