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Use expert opinions in your next audit

Healthcare Auditing Weekly, February 24, 2004

As an auditor or compliance officer, you are often unable to be an expert for all of the operations that create compliance risks, or it may be uncomfortable for you, as an insider, to point out the errors or wrongdoings of your colleagues. Bring in an outside source to review a compliance risk and confirm or eliminate any tensions surrounding your duties. Remember, consultants and experts should always work under the protection of attorney-client privilege.

Consider employees at the Centers for Medicare and Medicaid Services' (CMS) regional offices and fiscal intermediaries as sources of expert advice. They are often overlooked. CMS employees can tell you the agency's stance on a controversial provision, or maybe bring to your attention a position or interpretation of which you had no knowledge. You can even seek interpretive guidance from CMS on an anonymous basis.

Although you may ultimately challenge the CMS interpretation or guidance, the input will help you judge the possible reactions of intermediaries, CMS itself, or other enforcement authorities.

For more information on how to conduct an internal investigation, order the book "See for Yourself: A Guide to Conducting Internal Investigations and Audits." This book will show you how to conduct your own internal investigations and audits from start to finish. It offers practical advice and real-life examples on how to plan and staff an internal investigation or audit, and provides detailed information on the legal issues involved, such as attorney/client privilege, obstruction of justice, and legal obligation to disclose results. Click here to order.

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