Corporate Compliance

1. Strategies for examining diagnostic testing in the emergency room
2. Documentation improvement strategies
3. Gov't audit insider

Healthcare Auditing Weekly, July 1, 2003

Health Care Auditing Strategies
NEW Newsletter
Guide to Compliance Auditing: Applying OIG Techniques and Tools
Strategies for Health Care Compliance
July 22, 2003
Vol. 1, No. 12

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Sample audit programs (For subscribers to Health Care Auditing Strategies only)

Sample compliance policies and procedures. (For subscribers to Strategies for Health Care Compliance only)

The OIG Work Plan for Fiscal Year 2003

Ask the Expert

Tip of the Week

Compliance Hot Topics: Auditing, Billing and Coding, EMTALA, Stark, HIPAA

Question of the Week

In This Week's Issue

  1. Strategies for examining diagnostic testing in the emergency room
  2. Documentation improvement strategies
  3. Gov't audit insider

This Week's Headlines

1. Strategies for examining diagnostic testing in the emergency room

The urgent pace of patient treatment in the emergency room (ER) opens it to potential billing problems. That makes this an important area to audit and monitor for accurate documentation and coding.

Use the following seven steps in your audit:

1. Gather all necessary documents, including the following:

  • Paper chart for the ER
  • ER nurse and physician charts
  • Ancillary department paper charts
  • Printouts or access to electronic information
  • Order sets in electronic form (if possible)
  • Access to all diagnostic orders to substantiate billing
  • UB-92

    For the other six steps, as well as more information on auditing diagnostic testing in the ER, buy the pay-per-view article "Strategies for examining diagnostic testing in the emergency room." The article costs $10. Subscribers to the online version of Health Care Auditing Strategies have free access to it. Subscribers to the print edition can find it in their July issues.

    Or for only $23 per month, you can get even more auditing best practices and how-to articles by subscribing to Health Care Auditing Strategies. Save 10% by ordering online.

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    A how-to resource for conducting successful internal investigations and audits

    The new book, "See for Yourself: A Health Care Provider's Guide to Conducting Internal Investigations and Audits," 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.

    To order, or learn more, go to: Or, call 800/650-6787 and mention source code EB1054A.

    2. Documentation improvement strategies

    We can trace inadequate documentation to the root of the health care industry's current problems- from substandard patient care to financial loss. Documentation is the key to appropriate charge capture, and an incomplete or inaccurate record forces health information managers (HIM) to query physicians. That slows the billing process and, in turn, cash flow. Documentation errors lead to fraud and abuse, non-compliance with standards set by the Joint Commission on the Accreditation of Healthcare Organizations, and inaccuracies in statistical databases.

    Make sure your physicians are documenting appropriately. To help, purchase the handbook, "Documentation Improvement Handbook for the Medical Staff." Here's an example of the information this handbook offers physicians:

    Question: What are the best practices for documenting informed consent to minimize liability for myself as the treating physician and the facility?

    Answer: Informed consent for a procedure or anesthesia is a process between the physician and the patient, according to current legal opinions. As a physician, you have the responsibility to document that you discussed your assessment and recommendations with the patient, including the risks and benefits of the recommended course of treatment and other treatment options. If this discussion occurs between the physician and the patient (and sometimes the patient's family), it stands to reason that the physician should document this activity in the medical record. All too often, physicians count on a hospital's or other facility's staff to obtain a patient's signature on an informed consent form as adequate documentation.

    Physicians should sit down with the patient, including his or her family if appropriate, and dedicate adequate time and attention to the process of obtaining informed consent.

    Immediately after this activity, the physician should document in the medical record that the activity occurred and include a brief summary of the content discussed.

    To get the rest of this answer, as well as information on the need for clear handwriting, documentation requirements, and the time limits to complete medical records, order the handbook "Documentation improvement handbook for the medical staff." Click here for more information or to order.

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    Network with your audit colleagues

    "Audit Talk" is a new, moderated chat forum that members can use to post messages or questions for their peers 24-hours-a-day. "Audit Talk" offers a free forum to network, share ideas, and solve problems for those in the audit industry. Getting involved is easy. To subscribe, just send your request to this e-mail:


    Medicare cost reports and duplicate payments

    The Office of Inspector General (OIG) audited whether the costs claimed by Welborn Health Plans, Inc. on its Medicare cost reports were reasonable, allowable and allocable, in accordance with Medicare provider reimbursement guidelines. Welborn is a cost-based health maintenance organization under contract with the Centers for Medicare and Medicaid Services. In its audit, the OIG determined whether payments for provider services claimed on Welborn's cost reports were also reimbursed under the Medicare fee-for-service payment system.

    The OIG did the following to review the costs claimed on Welborn's cost reports:

  • Reviewed applicable laws, regulations, and Medicare guidelines
  • Reviewed and obtained an understanding of internal controls and procedures used by cost-based HMOs
  • Analyzed original working papers used to prepare and support the cost report
  • Reconciled Welborn claims data to the cost report

    For more information on the OIG audit report, "Audit of Medicare Cost Reports and Duplicate Payments for Welborn Health Plans for the Fiscal Years 1999 Through 2001 - Welborn Health Plans, Inc., Evansville, Indiana," go to

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    In addition to each 12-page monthly newsletter, Health Care Auditing Strategies (HCAS) subscribers receive the following benefits:

  • Audit talk-This is a free forum to network, share ideas, and solve problems for HCAS subscribers.

  • Audit advantage-Readers log on each month to the HCAS subscriber-only Web page that lists sample audit plans and government documents. Go to and enter the password that is printed in each issue of HCAS.

  • Fax and email alerts-When there's late breaking news that just can't wait until the next issue of HCAS, we'll fax or email the pertinent information to you immediately.

  • Editorial special reports-When there's a new regulation or news on laws related to health care auditors, our expert writers gather the necessary information and compile a special report. Subscribers received a free special report on the Sarbanes-Oxley Act with their May issues.

    Take advantage of these subscriber benefits, as well as auditing best practices and how-to articles by subscribing to Health Care Auditing Strategies. Save 10% by ordering online.


    To learn more about the Sarbanes-Oxley Act and how it affects internal auditors and compliance officers, order the special report "Sarbanes-Oxley Act: Impact on Health Care Organizations"

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