It’s fall and officially the time of year to start planning budgets and compliance work plans for next year. But, before sitting down to write a compliance work plan, did you perform a corporate compliance risk assessment? It’s crucial because key areas and priorities identified from your risk assessment will often transfer directly to your work plan.
If so, the next step, unless you have unlimited resources to address everything identified on your risk assessment, you’ll need to decide what to include in your work plan and how to make it accessible and effective. But don’t stress, I’ve sat down and put together some tips to help you narrow it down.
From policies and procedures to annual items there’s a lot to consider when planning your work plan. Honestly, it can be a little overwhelming. That’s why I designed these tips to make it a whole lot easier for you.
Let’s start with auditing/monitoring requirements.
A key area of any work plan will most likely include auditing plans involving billing. The OIG has said that compliance programs “should develop detailed annual audit plans designed to minimize the risks associated with improper claims and billing practices.”
Regarding an annual audit plan, ask yourself the following:
Is the audit plan re-evaluated annually, and does it address the proper areas of concern, considering, for example, findings from previous years’ audits, risk areas identified as part of the annual risk assessment, and high-volume services?
Does the audit plan include an assessment of billing systems, in addition to claims accuracy, to identify the root cause of billing errors?
Is the role of the auditors clearly established and are coding and audit personnel independent and qualified, with the requisite certifications?
Is the audit department available to conduct unscheduled reviews and does a mechanism exist that allows the compliance department to request additional audits or monitoring should the need arise?
If the error rates are not decreasing, has a compliance program conducted a further investigation into other aspects of the compliance program to determine hidden weaknesses and deficiencies?
Does the audit include a review of all billing documentation, including clinical documentation in support of the claim?