Corporate Compliance

Tip: Monitor potential risk areas

Healthcare Auditing Weekly, November 25, 2008

Auditing alone is not enough to maintain an effective compliance program—organizations must monitor all potential compliance risks on a regular basis as well.
 
The OIG considers monitoring to be an essential element of an effective compliance program: A well-designed and properly implemented monitoring program will help your organization identify potential problem areas. It also will help you validate compliance with the organizations policies and procedures.
 
The compliance officer must identify potential risks, topics to monitor, the process of monitoring, and the people who should perform the monitoring. At a minimum, monitor the areas listed in the OIG’s compliance-program guidance. Also be aware of areas your carrier or fiscal intermediary (FI) reviews. Follow these tips:
  • You the OIG has been conducting audits of pneumonia upcoding. Even if your organization’s rate of pneumonia coding is consistent with that of the rest of the industry, according to published statistics, ensure that there are quality-monitoring processes in place within the coding function. Monitor the function, not the outcome.
  • A hospital lab might monitor to ensure that all requests for lab work include a valid order that is signed by a physician and that includes a diagnosis.
  • You notice large spikes in critical financial accounts. If you find a potential program while monitoring these spikes, decide how to resolve it or conduct a comprehensive audit.
This tip is adapted from The Compliance Officer’s Handbook. For more information about the book or to order your copy, visit HCMarketplace.

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