So now you’ve finished your internal audit and have all sorts of new information. Likely some great outcomes and perhaps some that you weren’t expecting. What should you do next? There isn’t one absolute answer but all audit findings have to be looked at and evaluated for appropriate next steps. Some outcomes are more serious than others and will cause a more immediate response, while others may require nothing more than some re-education and follow up next year. Let’s break down some of the possible audit outcomes and next steps so you don’t feel like these fish.
Nearly perfect audit and no serious issues
Let’s say your audit findings were spectacular, nearly perfect, and no serious issues. I would say the next steps are a congratulatory communication and perhaps a “way to go” in your next newsletter.
Some areas of non-compliance but no serious issues
If your audit had some areas of non-compliance but none that rose to the level of an overpayment issue, regulatory or quality of care violation, or significant policy breach then perhaps an action plan might be in order. I like corrective action plans because then everyone is on the same page regarding the non-compliant activities, as well as, the corrective actions being taken. It also allows someone to do a follow up visit, or quick audit review to validate compliance. (Validation is an important component of demonstrating an effective compliance program)
Need for additional review
Those were the easy ones, right? Well what if your audit has identified a possible billing issue? One that requires additional review to determine the scope and severity of the problem and whether or not you have an overpayment issue. At this point, I would suggest talking with your Compliance Officer and in-house or outside counsel to provide direction and guidance about how to proceed with gathering additional information. If you have a possible overpayment, you must proceed carefully to stay within the 60-day ‘Overpayment Regulation.’ Whenever you find serious issues, I suggest bringing in your compliance officer and in-house counsel sooner rather than later.
No matter what your audit outcomes, it is a must to document from start to finish. By that I mean, document your audit rationale, the audit process, corrective actions and process improvement or changes you have made to systems, policies or procedures. Of course document all of the audit findings as you complete the audit.
If you identify an issue, you must address it. Having knowledge of an issue and not remediating it is worse than never finding it at all. Issues that are identified but never addressed are “prime pickings” for whistleblowers. So, when you identify an issue, address it, and correct it.
If you audit, identify, and correct the immediate concern, as well as, fix any systemic issues and document them, it will be hard for anyone to argue that you don’t have an effective compliance program. Remember, auditing and monitoring are an important elements of an effective compliance program.
Good luck and let us know if we can help in any way. We love your comments below!
Written by: Donna Thiel, Director of the Compliance Integrity Division