Corporate Compliance

Auditing against the OIG’s Compliance Program Guidance for Hospitals

Healthcare Auditing Weekly, May 9, 2006

Today we will continue our discussion auditing of against the OIG's Compliance Program Guidance for Hospitals with steps to ensure that your facility responds appropriately to detected offenses and develops adequate corrective action initiatives.

When auditing your compliance department's handling of investigations, identify whether your hospital accomplishes the following:

  • The compliance officer promptly investigates reports or reasonable indications of suspected noncompliance to determine whether a violation of applicable law or the compliance program occurred

  • The compliance officer is made aware of any overpayments, violations, or deviations and looks for trends or patterns that may demonstrate a systemic problem

  • Records of investigations contain the following information:

    - Documentation of the alleged violation

    - Description of the investigative process

    - Copies of interview notes and key documents

    - A log of the witnesses interviewed and the documents reviewed

    - The results of the investigation

  • The hospital uses sound practices and disciplinary procedures to consistently apply actions that result from an investigation

  • After a reasonable period, the compliance officer reviews the circumstances surrounding the investigation to determine whether similar problems have been uncovered

  • During an investigation, if the compliance office believes that the presence of certain employees under investigation may affect the investigation's integrity, those employees are removed until the investigation is complete, and the information-systems department suspends the employee's access to vital computer systems

  • The compliance officer takes appropriate steps to secure or prevent the destruction of documents or other evidence relevant to an investigation

      The above tip is an excerpt from the book "Hospital Auditing and Monitoring: Sample Programs for Key Risk Areas." Copyright 2004 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.

        • Strategies for Health Care Compliance

      • Strategies for Health Care Compliance

        News and real-life examples to increase the effectiveness of your compliance program. Strategies for Health Care Compliance...

      • Compliance Monitor

        This HTML e-mail newsletter delivers news on Medicare and Medicaid fraud and abuse, as well as recent documents and targets...

      • Medicare Weekly Update

        Each issue of Medicare Weekly Update includes the latest CMS proposed and final rules, CMS manual revisions, and...

      • Medicare Update for Physician Services

        Medicare Update for Physician Services is a free, monthly e-zine that delivers news and information to help physician...

      Most Popular

      Related Articles