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Designing a plan for ongoing compliance monitoring

HIM Connection, October 10, 2003

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TOPIC: Designing a plan for ongoing compliance monitoring

Ongoing monitoring is an intrinsic part of your compliance process. If designed correctly, your monitoring plan can ensure that you remain compliant in any risk-bearing procedures. While it is common to feel overwhelmed at the thought of creating yet another process within the usually overburdened HIM department, your department probably has many of the needed processes in place already; you might just need to enhance the documentation and feedback portions of your department.

Follow these tips to help you take stock of your current monitoring procedures.

1. List all monitoring processes currently in place in your department;

2. Analyze the contents of those processes;

3. Determine the parts of the processes that you should retain;

4. Assess where there are "holes" or areas that need to be enhanced in the monitoring process;

5. Decide if any of the current processes can be eliminated where new processes are needed.

Analyzing your current monitoring processes is a good exercise for your HIM compliance team. It will help them to develop and maintain a strong overall commitment to compliance. However, in redesigning the monitoring process, your HIM supervisors might need some additional guidance like how to determine baseline criteria for compliance, and how to determine any areas of weakness.

The remainder of this chapter addresses each area in the HIM department that you need to monitor such as:

*content and quality of documentation

*completeness of documentation

*coding and abstracting

*release of information (ROI)

*record retention and storage

This information is written with respect to current and potential areas of exposure. Note that at any time the government could add additional risk areas to its target investigations. You must keep abreast of these by following the Office of the Inspector General's (OIG) Compliance Program Guidance, as well as by keeping track of new investigations by the U.S. Attorney's office.

This week's HIM Connection was adapted from an excerpt of the book, "Seven Steps to HIM Compliance," by Ruthan Russo, JD, RHIT. Click here for more information or to order, and save $18.00 off the regular price.

Check out the Editor's Choice section below for a kit for training coders on the 2004 ICD-9-CM codes.

Sincerely,

Kate Alvarez
Editorial Assistant
kalvarez@hcpro.com

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