Home Health & Hospice Week

The last thing your agency needs is for surveyors to swoop in and accuse you of fraud or abuse.

Luckily, there is a simple way to keep your agency out of regulatory crosshairs: "Self audits provide ongoing monitoring to ensure your agency is compliant with the rules and regulations that impact the provision of home health services," explains Judy Adams, president and CEO of Adams Home Care Consulting in Chapel Hill, N.C.

Reality: While agencies have always needed to tow the line when it comes to regulatory compliance, "the increasing focus of Recovery Audit Contractors and Medicare Administrative Contractorsmeans that agencies can't afford to discover errors, omissions, or incomplete documentation from the external reviews when it is too late to make the necessary changes," Adams notes.

A self audit also helps agencies spot their "practices -- both good and bad -- and correct them when needed rather than to repeat those mistakes over and over," adds Tom Boyd, a consultant with Boyd & Nicholas in Rohnert Park, Calif. Follow these best practices to perform your own self audit -- before your bad habits lead you down the wrong path:

• Appoint the appropriate auditor. Your first step in conducting a self review is to figure out which staffers should complete the audit. The team you choose should have training, experience, and working knowledge of the rules and regulations so that they know exactly what they're looking for and can easily spot any red flags.

Key: Make sure your auditors never review their own records. Not only is catching your own mistakes more difficult, but "the staff member generally would have documented differently if he or she thought there was something else needed," Adams says.

• Perform audits regularly. While it's nice to think that one audit will correct all your mistakes and keep your agency on regulators' good sides forever, that line of thinking is inherently flawed. Staff members come and go, situations evolve, and rules change. That means you must schedule self reviews on a regular basis to ensure you don't fall back into old bad habits or establish new ones.

Frequency: "Quarterly reviews are recommended," but every agency should decide for itself how often to perform a self audit, notes Adams.

Other options include performing a few reviews each month or combining the review with quarterly record review required under the Medicare Conditions of Participation.

• Target the right number of files. You don't need to look over every file for every patient, Boyd says. Rather, focus on a representative sample that could reveal trends.

Do this: Tell your auditors to pull 10 percent of the open and closed episodes for the past quarter. When reviewing them, look for common red flags as well as simple documentation or coding mistakes, Adams advises.

Examples: Adams outlines these common red flags that auditors should be on the look out for when they examine your agency's files:

• Know when you need help. Your staffers will likely do the lion's share of your self monitoring, but it is "certainly useful to have an outside person do at least an annual review to have an even more objective review," Adams points out.

How: You could choose to swap files with members of another agency so that they audit your files while you audit theirs, or simply bring in an expert who is qualified to look at the range of requirements agencies must address -- from ICD-9-CM coding and OASIS assessments to determining outcomes, medical necessity, and appropriate coverage, Boyd suggests.

However you choose to outsource or supplement your self audit, make sure that you outline your plan in your policy and procedures, and that you keep all patient information safe, he stresses.