Nothing is more daunting than receiving a notice from the Center for Medicare and Medicaid Services (CMS) of an impending audit. The anxiety intensifies when the notification is a result of reported Medicare fraud. Anyone can file a suspected fraud notification to CMS: a patient, disgruntled employee, vendor, or another insurance company that is a secondary payor to Medicare. A qualified Medicare fraud lawyer in San Francisco, CA can help you prepare and tackle an audit. We at the Morales Law Firm have put together four tips on preparing for an upcoming CMS audit.
Review Your Policies and Procedures
It is embarrassing when employees do not know company policies and procedures. Staff are good at creating workarounds so much so that they forget what the actual policy says when performing specific functions on patients. Some staff may even skip a step or two. The patient is notified of each claim submitted to CMS, and such notification contains contact information for Medicare advising the patient to call for suspected fraud. Today, patients are savvier with understanding these notices and will call Medicare if a procedure listed on the notification was not performed. Reviewing the policies with the staff will also help identify employees who are not in compliance.
If you find that many employees are skipping a particular step, then it may be time to revisit your training procedures, or it may be time to look at what you can use in the workplace to remind staff of certain steps such as with posted signs.
Draft an Audit Strategy
Identify your strongest employees (compliance officers or quality managers are preferred) to lead the audit. Runners who can retrieve patient-specific data often requested during an inspection are also helpful to have on standby — and a go-to person to answer questions from CMS auditors. If the audit notification resulted from suspected fraud, contact an experienced Medicare fraud lawyer to help you get organized immediately; the sooner you contact an attorney, the better!
It also helps to have open conversations with your employees to determine what areas they see that need improvements. Perhaps they are skipping a step in the procedures for an important reason such as administering some sort of life saving medication. Knowing this will help your organization overcome issues in the future.
Review Compliance Program Deliverables
If your organization was required to draft a corrective action plan after a previous CMS inspection, review the plan to ensure that each action item has been met. Be prepared to address outstanding action items that have not been resolved. Your organization should perform a root cause and formulate a plan to meet the goals.
A mock audit or tracer is a good way to prepare your staff for an audit. Identify the most current CMS program audit protocols and ask your team targeted questions to assess their readiness. Write down each area of weakness and educate the staff accordingly. If your facility has been suspected of fraud, contact a Medicare fraud lawyer for assistance immediately.