Medicare Compliance & Reimbursement

Be ahead of the charge with a fail-safe, audit-response plan.

No matter how careful you are Medicare audits happen. But how you respond and prepare can make all the difference when the auditors come to call.

If a Medicare Administrative Contractor (MAC) or another audit contractor sends you a scary letter that your agency has been scheduled for an audit — often the next morning to give you little time to prepare — it’s easy to panic. “The first response to audits is fear,” Vera Watkins, RN, CNOR, CHA, CHCO, OHCC, CCRC, perioperative nurse at Retina Specialty Institute and certified health auditor, told attendees at the American Academy of Ophthalmology 2016 annual meeting in Chicago.

Taking these immediate steps will serve you well if you get a letter:

1. Verify the address. The first thing to do is to confirm that the full address on the letter is correct, advises attorney George F. Indest III, President and Managing Partner of Orlando-based The Health Law Firm.

In his Medical Economics article, “19 Tips to Prepare You for a Medicare Audit and Site Visit,” Indest warns that if you haven’t updated your physical address — or if your current address is incomplete — in the Provider, Enrollment, Chain and Ownership System (PECOS), auditors may not be able to find you, putting your Medicare billing privileges in danger of being terminated.

2. Contact the auditors and confirm exactly when and where the audit will take place. Give auditors any codes they need to access parking garages, buildings, and so on, recommends Indest.

3. Alert your attorney. Provider leadership should ask their attorney to be present during the audit and site visit, says Indest.

4. Organize your office. After making those calls, visually inspect your office, Indest advises. Are all desks, cabinets, and closets clean? Make sure all certifications and degrees displayed in the office are up to date.

5. Designate one member of your staff to liaise between the auditors, your practice, and your attorney. This person should be present during the audit and stay with auditors as they tour your office.

6. Ask for ID. When auditors show up at your door, make sure they present their IDs and letter of intent. Make a copy of their IDs and escort them to a private room. “Don’t let them wander around your office because they’ll talk to anyone,” said Watkins.

7. Make copies for your files. Whenever auditors ask you for a copy of a document, make two copies and keep one for yourself.

When Auditors Leave

If auditors find an issue with your agency, you’ll need to develop a Corrective Action Plan.

The compliance team should conduct a root cause analysis of the issue, develop an action plan, and engage all staff members in implementing it. “Nothing drives behavior like data,” said Watkins. When trying to get staff to change the way they perform a process, show them data that proves why the change is necessary.

Just doing their job: Even though audits are anxiety-producing, Watkins offers providers some comfort: “You’re never going to have a 100 percent clean audit. Auditors are hired to find something wrong.”