The word “audit” leaves most people with a sick feeling in their stomach
Taxes get audited. Insurance companies audit medical records. It is often thought of as something that is done to us and has a negative outcome. Rather than waiting for something bad to happen, decide to take a proactive approach and evaluate your current situation with a baseline audit and review.
A baseline compliance audit can measure a number of things: coding, documentation, new patient processing systems, billing/collections, patient case management, marketing practices, or your compliance related to HIPAA, OSHA, and CLIA, if applicable. It measures your practice’s performance against industry requirements, state and federal regulations, and your contracts with third-party payers. Just as the name implies, baseline audits help you establish a reference point of your practice’s current policies and behaviors and will allow you to set measurable goals on how to improve. Think of it as similar to a new patient’s x-rays and exam findings - it’s a snapshot of the subluxations in your practice.
Self-auditing confirms your commitment to professionalism and integrity
Although these audits are internally driven, they are meant to be completely objective in order to show you exactly what would be discovered in an outside audit or investigation. Yes, the truth can sometimes be difficult to hear, but by uncovering these issues yourself you can potentially avoid the catastrophic financial losses of a post-payment audit with mandatory recoupment or the penalties associated with non-compliance. When you learn to perform self-audits or hire a company to perform them on your behalf, it confirms your commitment to professionalism and integrity. You become better equipped to correct compliance issues and, as a surprising benefit, may be able to find more efficient and profitable ways to run your practice.
A true baseline practice audit should contain these key items:
- A minimum of ten charts per provider should be completely audited for documentation, coding, and billing as well as adherence to utilization guidelines.
- A baseline coding audit should be conducted for evaluating monthly code usage for at least the prior twelve months. Comparative analysis should include a review of Evaluation and Management Coding, chiropractic manipulative treatment coding, modality and procedure coding, and all other ancillary services provided to patients. This review should be conducted for each physician in the practice.
- A review of existing policies and procedures installed in the practice should be conducted to assess what is in place and what should be added.
- A measured review of your existing HIPAA compliance program to assess privacy and security in your practice.
- An assessment of your state specific-licensing, advertising, and marketing to ensure adherence to regulations and laws. This includes letterhead, business cards, signage, etc.
- Validation of all employees’ status and non-exclusion from Federal or insurance programs. This should include business licenses, professional licensure and certifications, and appropriate local tax licenses.
- An analysis of any existing third-party contractual obligations and agreements to ensure full compliance with your obligations and expectations.
While this may seem like a large undertaking, it is a necessary step to begin the implementation of a compliance program in your office. You won’t know what to fix if you don’t know what’s broken. It is ok if you find mistakes initially. The feedback will allow you to strengthen the policies and procedures in your office to ensure that they won’t happen again.
Once complete, your report from the baseline audit should include the following information and data:
- Audit Report per Provider: Error rate data and regulations for identified errors should be included in the final report, as well as the summarized reports for each provider reviewed.
- Provider Recommended Education: All identified errors should have a crosswalk to recommended training for each. This should also include the “by when” that training is to be conducted. For example, if the audit revealed that treatment plans were spotty and indicate that some additional training on the requirements of treatment planning is necessary, detail HOW and WHEN that will take place. Set a time to review the progress, evaluate again, and hopefully, show progress.
Just as you would perform re-exams on your patients, follow-up audits are critical to assessing the progress that you are making. If you found that your error rate was 10%, you may only need to schedule follow-up auditing annually. An error rate of around 40% would necessitate an additional audit every six months until your error rate has improved. If you find that you are bordering between 80-100% error rates, audits must be done much more frequently, about once a month, to chart improvement.
If your office lacks the systems, compliance, and documentation of critical office error statistics and action steps taken to improve, now is the time to get started. Schedule your Discovery Consultation today to gain an understanding of where you are now, so you can take the steps necessary to identify areas requiring improvement. Then, watch how smoothly your office runs with correct and proper systems and standards!
Dr. Karen Sedore has over 10 years of experience working in the chiropractic profession. She began as a manager specializing in billing and medical necessity as well as taking on chiropractic assistant responsibilities so that she could be more involved with patient care. She also has experience with income tax preparation and has helped hundreds of families and small businesses with tax planning. In 2016, Dr. Sedore received her doctorate in Chiropractic from National University of Health Sciences. She joined KMC University in 2017 and assists doctors and their staff in her current role as an Membership Advisor.