How to prepare
As I was sitting down to write this blog today, I was reflecting on some of the things I learned from the Quality Monitor I worked with during my oversight of my company’s Corporate Integrity Agreement (CIA). The Quality Monitor’s role was to visit centers with us, and provide insights on how to improve our overall quality and how to help me improve as a compliance officer. These things helped in preparing for a health care compliance audit. One important message we heard consistently was to “verify and validate”. As you begin to prepare, think about how you will verify and validate the information you are gathering.
Verify and validate
One important way to do this is to conduct staff interviews because it provides valuable “in the field data” from the people working in healthcare. The auditors will also establish a rapport with the staff. These are both important components of an effective health care audit, but in the end you have to see the process, documentation, and/or outcomes to truly verify and validate.
What tools and where
Next you have to decide whether you will you be conducting your audit on-site, or through data analysis or phone interviews. In order to be effective you need to properly prepare, so take time to consider what tools you will be using.
Define the risks
First, you should clearly define the risk or risks which led to the audit. For purposes of this blog we will “assume” you have completed a risk analysis and this step is completed. (Good job.) We’ve also included a link below on how to implement risk assessments.
The outcomes
When putting the process together, ask yourself what outcome(s) are you trying to achieve? Is it a risk validation or an assessment of a risk. If it is a risk assessment you might consider using a scoring system so that you can more easily communicate the severity of the risk.
It may also help you determine if additional risk monitoring is necessary. For a risk validation it might be as simple as a yes or no measurement.
Identify the people
Now, identify the people and/or systems that either have the knowledge to talk to you or contain the data you need to review. Familiarize yourself with all of the associated policies and procedures as well.
Now you should be ready to identify who to interview, what data to review, and what policies or procedures to monitor (validate/verify) for compliant implementation.
Tools
Create your tools, communicate your expectations, and go out and verify and validate what is happening in your health care organization.
The final steps are understanding the data you collected, communicating your findings, and implementing corrective actions – but those are for future blogs, so stay tuned and good luck!
Donna Thiel
Here to help compliance officers get a good night sleep.
