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Conducting Stark audits: Part two

Healthcare Auditing Weekly, July 5, 2005

Last week, we reviewed the first steps auditors should take to ensure compliance with Stark. This week, we'll go over the final four. After reading the Stark regulations, identifying all compensation arrangements, and interviewing key staff members, follow these steps:

1. Assess physician performance by reviewing the following:

• Performance reviews
• Timesheets
• Compliance with contract terms

2. Assess whether the agreement meets an exception by considering whether the contract:

• is in writing
• includes a term and termination
• identifies compensation methods

3. Review contract documentation.

• Review timesheets, reports, and reviews
• Determine whether physicians have disclosed any conflicts of interest, such as their family's ownership interest

4. Identify potential conflicts of interest.

• Talk to contract managers to determine how each contract was negotiated
• Review the contract manager's relationship with physicians
• Investigate whether the contract manager reviewed the government's database to determine whether the physician has any ownership interests in a business within the state where the hospital does business

The above tip is an excerpt from the book "Hospital Auditing and Monitoring: Sample Programs for Key Risk Areas," copyright 2005 by HCPro, Inc. This book is a step-by-step, practical manual that offers sample audit programs for the most troublesome areas that a hospital must audit. The binder and CD-ROM are filled with actual audit programs used by auditors and compliance officers in the field. Click here for more information or to order your copy today.

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