Corporate Compliance

1. Techniques for compliance assessments
2. Find and monitor all conflicts of interest in your organization
3. Gov't audit insider

Healthcare Auditing Weekly, August 6, 2003

Health Care Auditing Strategies
NEW Newsletter
Guide to Compliance Auditing: Applying OIG Techniques and Tools
Strategies for Health Care Compliance
August 5, 2003
Vol. 1, No. 14

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

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In This Week's Issue

  1. Techniques for compliance assessments
  2. Find and monitor all conflicts of interest in your organization
  3. Gov't audit insider

This Week's Headlines

1. Techniques for compliance assessments

You know that it is essential to conduct compliance assessments, but do you know whether you are conducting these assessments efficiently? Use the following tips to evaluate your compliance program assessments:

Conduct the analysis of your compliance process at least annually, and include techniques such as the following:

1. On-site visits
2. Interviews with personnel involved in management, operations, coding, claim development and submission, patient care, and related departments
3. Questionnaires developed to solicit impressions of a broad cross-section of the organization's employees and staff
4. Reviews of medical and financial records and other source documents that support claims for reimbursement and Medicare cost reports
5. Reviews of written materials and documents
6. Trend analyses or longitudinal studies that seek deviations, positive or negative, in specific areas over a given period

Use a variety of methods to support the validity of your compliance process audit findings. Use those listed above, or additional ideas that may be germane to your organization.

Supporting documentation:

  • Copies of reports on the compliance program, including instruments that will indicate use of various auditing techniques, such as interview transcripts, questionnaires, financial and billing reports, continuous quality improvement trending, and tracking reports
  • Reports to senior management and the governing body on compliance indicators
  • Corrective actions taken as a result of compliance audits and reviews

    For more information on hospital compliance program assessments, click here The book and CD-ROM set, Hospital Compliance Program Assessment: Your Tool for Measuring Effectiveness, will help your facility conduct thorough compliance program assessments. It provides standards based on the OIG Compliance Program Guidance for Hospitals and a rating system for determining your level of compliance with each standard, both developed by the author. There's also an explanation of how to meet the standard, and a list of documents you need to prove that you meet each standard.

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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.


    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.

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  • 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.

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    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.

    2. Find and monitor all conflicts of interest in your organization

    Last year, it was impossible to miss the endless barrage of news stories about executives whose conflicts of interest spelled disaster for their companies. Now, it's more important than ever for health care organizations to make sure their conflicts of interest policies and procedures really work.

    Use the following 12 steps to audit your conflict procedure:

    1. Obtain a list of personnel with purchasing capabilities from the information services department. Trim down that list to include workers with primary purchasing responsibilities only; make your choices based on their job functions and positions within the organization.

    2. Find out the personnel who last mailed conflict of interest forms. Include all administrators, physicians, and board members. Also, obtain a list of current board members and their places of employment. For more information on auditing conflicts of interest, plus the other 10 steps to this audit program, order the pay-per-view article "Find and monitor all conflicts of interest in your organization." 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 January 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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    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:


    Home health agency billing

    The Office of Inspector General's (OIG) objective for this audit was to determine whether home health agencies were billing for services that were preceded by an inpatient hospital discharge in compliance with Medicare prospective payment system (PPS) regulations. The OIG used the following steps in its audit:

    1. Reviewed applicable Medicare laws and regulations.

    2. Extracted the home health agency PPS claims data for Associated Hospital Service (HAS) claims from the National Claims History (NCH) file for services rendered during fiscal year 2001.

    3. Performed a computer match of this data to each beneficiary's inpatient hospital data in the NCH. This was done in order to obtain a data file of "K" and "M" claims with hospital discharge within 14 days of the home health agency episode. Note: HHAs submit claims for services that are not preceded by an inpatient hospital discharge within 14 days of the HHA episode with an additional one point in the services utilization dimension resulting in the assignment of a "K" or "M" in the fourth position of the HIPAA code.

    4. Selected a stratified random sample of 100 "K" paid claims and 100 "M" paid claims.

    5. Obtained the common working file data for sample home health agency claims and the corresponding inpatient hospital claims and recalculated the correct payment for the sample claims to determine overpayment amounts.

    6. Met with representatives of judgmentally selected home health agencies to validate billing errors and determine the underlying cause of noncompliance with Medicare billing requirements.

    7. Used a stratified variable appraisal program to estimate the overpayments to home health agencies under the payment jurisdiction of AHS.

    8. Discussed the results of the review with AHS officials and provided AHS a file containing the population of claims with payment errors for recovery.

    Click here to read the audit report "Review of Payments Made by Associated Hospital Services for Home Health Services Preceded by a Hospital Discharge."

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    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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