There seems to be a problem-Now what should I do?
Health Care Auditing Strategies, February 1, 2005
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It may be the hardest part of an auditor's or compliance officer's job-deciding what to do when there's an instance of wrongdoing.
Whether the nature of the matter is medical or financial-or whether it's based on cost reporting, claims filing, documentation, licensure, or certification-each situation requires nuanced analysis.
General rules for next steps are not always easy, says Donna K. Thiel, Esq., a partner in the Food and Drug Administration/healthcare regulation practice at Latham and Watkins in Washington, DC.
"In general, you are not going to shoot a mouse with an elephant gun. If the problem is small and isolated, you may just report to the intermediary. If it is potentially a larger problem, you might go to the OIG but not without full understanding of the issue and careful consideration of the consequences," Thiel says.
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