Practice Management Alert

Warning: If you don't conduct your internal audits correctly, you could be hurting - not helping - compliance at your practice.

Investigators will be suspicious of internal audits if you're not careful, says Wayne Miller, an attorney with Compliance Law Group. As inspectors see it, an internal auditor may be apt to overlook a problem because she simply doesn't know the correct billing procedure. Also, depending on the office environment, an employee acting as auditor may hesitate to point out problems because of how the office has handled them in the past. 

An internal audit needs to be done extremely well to be a convincing compliance effort, says Miller, who presented in a recent Coding Institute teleconference. Use these five expert-endorsed strategies to make your internal audits completely compliant. 1. Check your compliance plan first. Many billing offices don't realize that their compliance plan actually calls for an independent audit. If you conduct audits differently than your compliance plan mandates, investigators will see a poor commitment to compliance. 2. Your internal auditor should be an expert at gathering and interpreting statistical information, says Brenda Burton, president of MedExtend in Fayetteville, Ga. If your auditor is inexperienced, invest the time and money to train her. 3. The claims management supervisor and compliance officer should get together to review audit procedures as well as report findings, Burton says.  4. Take prompt corrective action to amend any problems found. And "document absolutely every step of the audit and results!" Burton says. Remember - diligence is the best way to avoid liability. 5. Have an external source - an auditor or other qualified consultant - review the final reports. Be open to any recommendations on how to improve. An external review of your audit is very important because it adds validity to your billing practices and shows your commitment to compliance, Burton says.  How long should you hang on to audit reports and documentation? Experts agree that you should keep audit reports and documentation of problems you're addressing for about 10 years. Most fraud claims and other investigations will probably occur within a five-to-seven-year range, but keeping everything for 10 years will ensure that you're safe.
See "What to Watch Out for in 2004" , this issue, for a list of OIG Work Plan focus areas to include in your internal audits.