Management Structure How Did We Get Here Getting the Attention of Senior Leadership Those Sticky Audit Reports

Transcription

1 Patricia Ariel, CHC SVP, Chief Compliance Officer Internal Audit & Compliance Westchester County HealthCare Corporation Donna Abbondandolo, CHC, CPHQ, RHIA, CCS, CPC AVP of Compliance Catholic Health Services of Long Island April 22, 2015 Management Structure How Did We Get Here Getting the Attention of Senior Leadership Those Sticky Audit Reports Simple to Complex Audit Reports Audit Findings: recommendations to material issues Communicating in the organization Creating the Dashboard Getting the Board Engaged Board Presentations 1

2 BOD President & CEO Compliance Officer EVP & SVP VP Directors Managers & Supervisors What were the constraints? Audits, Investigations, CAP s, Education Structure-department head, VP s Unanswered questions Open action items Missing information/documentation Lack of response from middle management Policies and Procedures Management responses to findings 2

3 What did we need to happen? Linking the manager with the Senior Leader for knowledge Communication Response Ownership Accountability Audit Report Types: Standard: Minimal findings: error rate <3% No financial risk Room for improvement Operations shortfall Management Response, i.e. level of Corrective Action Plan (CAP) Format? What do you use as a final report? (i.e., ppt, word document, etc.) 3

4 Standard continued: Random sample: small size, <35-50 Perhaps pre-bill? Temperature test: Do we need to look further? Do we need to improve process New line of business New service New management Audit Report Types: High Risk: Findings > 5% error rate Some financial risk Regulatory weakness identified Do we have further obligations? Operations shortfall Management discussion, i.e. CEO? Senior Management, Department Heads 4

5 High Risk continued: Retroactive? Privilege prior to starting? Do we have information about the audit where issues have been identified? Is management collaborating and kept in the loop as the audit is on-going? CEO involvement? Audit Report Types: Complex Report, High Risk: Review stopped Privilege & Confidential High financial risk Regulatory weakness identified Obligation Management discussion, i.e. CEO? Senior Management, Department Heads General Counsel Discussion Outside Counsel Potential Disclosure Board involvement? 5

6 Concepts were the drivers: Formal Audit process Traffic Lights Access and Communication Elements of the program Education markers, communication tips, audits Library-industry information Audit WMC Contact Audit Stage Status Comments Issued in Final Form November 2014 Completed High risk findings included: Gaps within CDM maintenance process. Outdated policy for charging supplies. No formal policy to revise and update charge tickets, forms and charge entry screens. Front-end clinical staff does not have depth of understanding of appropriate charge capture for procedures and tests. Laboratory registration staff does not comply with ABN requirements. Except for those departments coded by HIM, there is no self-monitoring of coding or charge capture for outpatient services. Issued in Final Form October 2014 Completed High risk findings included: Current versions of Administrative Policies and Procedures not adopted. Current version of Notice of Privacy Practices not utilized. Issued in Final Form November 2014 Completed High risk findings included: Discharge summaries not dictated within 30 days of discharge. Illegible handwriting Incorrect coding of secondary diagnoses. Secondary diagnoses not coded. Procedures not coded. 12 6

7 Clear Reporting: Boards want upfront clear portray state of business Boards don t have time or attention span to tolerate vagueness or fluff in reporting Keeps the business on track Instills Board confidence Keeps alignment with business goals Board Members Support: Establish Relationships Fosters a sense of responsibility & obligation to you Establishes a sense of loyalty Credibility: Clear and precise reporting 7

8 Information is Influence: Board Interactions How are you perceived as a leader Right information Right time Right format Assessing the outcomes: Financial risk? Significant financial effect Self Disclosure Media risk? Settlement Agreement? Public Report? Management Discussion General Counsel/Outside Counsel CEO Board Verbal discussion of with the Board Audit & Compliance Committee Full Board Report 8

9 Best Practices Written audit reports Final Reports Summary Reports Hand out? Secure web site? Dashboards Create your dashboard report Upload to a secure site Hand out? Audit in Progress WMC Contact Audit Stage Status Comments Delayed Delayed 2014 Special Request Audits Audit in Progress WMC Contact Audit Stage Status Comments Delayed Delayed 18 9

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11 Patti Ariel, CHC SVP, Internal Audit and Compliance (914) Donna Abbondandolo, CHC, CPHQ, RHIA, CCS, CPC AVP of Compliance (631)