Audting and Monitoring
The role of auditing and monitoring goes hand in hand with an organization’s compliance plan and is the mechanics of operating the program after other steps have been accomplished. An effective compliance program has a process of constant evaluation.
The OIG compliance program guidance states ongoing evaluation is critical to a successful compliance program. In addition, the OIG indicates that all Corporate Integrity Agreements (CIA) have regular monitoring minimally on an annual basis.
Reliable auditing and monitoring includes all aspects of facility operations and takes into consideration the compliance program. A significant component of an effective compliance program per the federal Sentencing Guidelines is to detect criminal conduct and errors.
How can Harmony Healthcare International (HHI) Help?
Harmony Healthcare International (HHI) can assist with development of effective auditing and monitoring processes which are reliable, workable and produce results that enhance processes, outcomes and systems and include some of these basic elements:
- Specifically identify and target what will be monitored
- Identify specific action steps of the monitoring process for what will be audited
- Identify a communications plan for how intelligence gathered from auditing and monitoring will be shared and used within the organization
The results from regular auditing creates data that can be used to track successful implementation of initiatives built around areas of risk identified in the risk assessment and described in the Compliance Plan. The data is then used to adjust processes that directly influence the identified risk area initiative performance and ensure that providers know if they are complying with substantive laws as well as policies and procedures. These results are the basis for Annual Compliance Plan reporting to the Board of Directors.
The OIG recommends audits focus on programs or divisions that may include third party contractors to ensure Integrity of audits and subject matter experts. Harmony HealthCARE Specialists assist providers with:
- Developing an Auditing and Monitoring Plan
- Assist with Risk identification through Risk Analysis
- Conduct audits identified from Risk Analysis
- Selection of Monitoring Tools
- Determination of sampling size for Audits
- Assessment for internal investigation
- Education and training
Areas of potential exposure that should be considered as part of the Compliance Plan and the Auditing and Monitoring plan as potential risk area are as follow:
- Anti-kickback and self referral issue
- Credit balances
- Bad debts
- Claim development and submission
- Record retention
- Cost reporting
- Compliance program processes
- National background checks
- Documentation supporting claim submission