Harmony Healthcare Blog

Want To Avoid an Audit? Remember to PREPARE

Posted by Washington Health Care Association on Thu, Oct 16, 2014

This is a featured guest blog article written by: 

WHCA - Washington Health Care Association



On Thursday, October 9th, Kris Mastrangelo, Owner and CEO of Harmony Healthcare, presented a webinar entitled “The OIG Report: Best Practices in Audit Prevention.” The report makes strong statements regarding alleged MDS inaccuracies, over coding, and billing by skilled nursing facilities. Mastrangelo outlined keys to success to help communities avoid audits and find success with their compliance programs with the acronym “PREPARE”:

  • Policies and Procedures: Write specific policies and procedures for your facility. There are many available “for purchase” solutions; however, Mastrangelo points out that each facility has unique staffing, residents, and personalities that need to be specifically addressed. Furthermore, these documents should not live on a shelf gathering dust, rather they should be living documents that are reviewed and updated regularly to meet your facility’s ever-changing situation. Most importantly in putting together policies and procedures: make them easy to read! If you want your staff to follow them, they need to be able to understand what they’re reading.

  • Reporting and Investigating: In your facility you should strive to create an atmosphere that harbors smooth and clear communication when it comes to reporting. You want people to feel comfortable about coming forward with problems or issues that they see. You also want to be sure that your channels of communication are working. Mastrangelo shared that she has visited many facilities that have 1-800 numbers posted, but that, more often than not, it is either disconnected or just rings without anyone picking up.

  • Education and Training: “The number one reason for non-compliance is the lack of training,” said Mastrangelo. The goal with education should be to change behaviors and empower your staff to make the right choices. Find moments to provide meaningful trainings throughout the work week. It could be during a daily stand up meeting that you have during the work day with a specific department, or an all-staff meal; whenever you find the time, make it meaningful and avoid being too routine. Remember: things won’t always stick with your staff; be sure to retrain them often on policies and procedures.

  • Prevention and Response: Simply put: be prompt. When you have feedback, review it internally as soon as possible. Get your compliance board together, figure out what happened, and what’s going to be done to fix it. The longer the issue lingers, the less potency your compliance program will have among your staff.

  • Auditing and Monitoring: “The higher the level of independence an auditor has in relation to an organization, the greater the integrity of the audit,” says Mastrangelo.  Auditing is a third-party task that should be done regularly to help monitor compliance, identify problem areas, and assist in the reduction of identified problems. Monitoring falls directly to the facility. Oftentimes facilities will identify and fix issues but fail to monitor them to ensure that the issues won’t reoccur. You need to be willing to track and correct any residual issues that your facility faces to avoid having to readdress it down the line.

  • Responsibility/Oversight of Compliance Officer/Committee: The first question you need to ask when choosing a compliance officer, according to Mastrangelo, is where he or she will fall on the org chart. The compliance officer should be placed in such a way that he or she reports directly to top leadership whether that be the board, CEO, or administrator. The compliance officer, along with the compliance board, will be responsible for creating, implementing, updating, and tracking your facility’s compliance program. Give them the time and resources that they need to effectively handle the task.

  • Enforcement, Discipline, and Incentives: It is essential that you are clear with staff on your facility’s expectations and the consequences that will result in the case of violating them. Employees should understand that they must abide by the law, the facility’s code of conduct, and compliance program stipulations. With that, employees must understand that they have a responsibility to report anything suspicious that they witness, and that they will be held liable if they fail to do so.

For more information on Medicare and Medicaid audits and compliance you can follow Kris Mastrangelo (
@KrisMastrangelo) and Harmony Healthcare (@Harmonyhlthcare) on Twitter.  

You can see Kris speak in person at this year's SNF Interdisciplinary Conference: HARMONY 2014 - November 6th & 7th at Foxwoods Resort Casino in Ledyard, CT.  

For more information about HARMONY 2014 - click here.

About Washington Health Care Association  (WHCA):

The Washington Health Care Association (WHCA) is a statewide non-profit organization representing over 400 assisted living and skilled nursing facilities.Did you miss the WHCA webinar? Follow WHCA on LinkedInTwitter, and Facebook and visit them on the web at https://www.whca.org/ to stay up to date on all upcoming WHCA events.

 PEPPER Analysis

Topics: Documentation, OIG, Compliance, Audits,

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