Home Health & Hospice Week

Although an audit is a routine function that the OIG and payors must perform, it can strike fear into the hearts of home care providers everywhere. If you get word that you will soon be audited, follow these tips to help put your best foot forward.

Don't wait until the HHS Office of Inspector General or your contractor alerts you that an audit is imminent before you get a handle on whereyou stand from a compliance standpoint, says Patricia A. Trites of Healthcare Compliance Resources in Sherman, Texas.

"Internal audits are the best way to prepare for an external audit," Trites advises. "This process allows [you] to find errors and patterns of errors before someone else does."

Next: "The second step to internal auditing is just as important -- education," Trites says. "If the providers don't know or don't understand why something is incorrect or why another way is better, then the errors are never corrected going forward."

Once you know that an auditor is coming, sit down with your staffers to fill them in on the details. Although it may be tempting to keep the audit a secret so you don't make anyone nervous, it's in your best interest to keep everyone apprised of the situation.

"I really do believe it is important that affected staff are trained before the auditor comes onsite or even if records are being requested for audit through the mail," Trites advises. "Staff that know what is going on are less likely to start rumors or listen to rumors."

Let staffers know that they should be polite and respectful to the auditor, "and to always, always, always tell the truth," Trites says. "There are so many types of audits that could be undertaken within a healthcare practice today it is hard to cover all the bases of what-ifs, but I suggest that staff understand that an audit does not mean that the organization or any of the providers have done anything wrong."

Keep in mind: Many audits are conducted to determine if the Medicare contractors are doing their jobs correctly. Does that mean if they find something your organization has done incorrectly, you will get a pass? "No," Trites says. "That is why it is important that each person understand their responsibility and liability in performing services, documenting those services, and then billing the services."

If you have never performed a self-audit, but you get word that you'll soon be audited, Trites offers these five tips:

1. Don't panic! Auditors aren't necessarily on a witch-hunt.

2. Pull all records that have been selected for audit with all of the accompanying documentation.

3. If you believe there may be a problemwith your claims or how they were billed, contact an attorney to help you through the audit process. If not, move to step 4.

4. Perform an internal audit of the claims and if necessary, hire an external auditor to also review the claims. It's best to let your attorney "engage the external auditor to protect the reports under attorney work product," Trites says.

What this means: If the attorney hires the consultant, the work performed during the audit falls under the attorney-client privilege, says attorney Michael F. Schaff with Wilentz, Goldman and Spitzer in Woodbridge, N.J.

5. If there is a problem, do not alter documentation, alter billing records, destroy records, or in any other way compromise the information, Trites says.