June Hospice Fundamentals All Rights Reserved 1. Avoiding the Top Ten Auditing & Monitoring Blunders. Plan for This Session

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1 Avoiding the Top Ten Auditing & Monitoring Blunders Subscriber Webinar Plan for This Session The case for auditing and monitoring Common mistakes and how to avoid them Deciding where to focus efforts OIG Compliance Plan Guidance OIG Element #6: Conduct internal monitoring and auditing Prioritize compliance risk areas, determine how to monitor and audit them, make a schedule and stick to it A fundamental component of effective compliance program Regular reporting to senior management & Board All Rights Reserved 1

2 It s about assessing the state of your hospice! Purpose of Monitoring and Auditing Unmonitored key processes (and therefore results) tend to decline over time Designed & implemented correctly Provides information concerning effectiveness of key processes problems timely Helps know where to focus education and process changes Produces more accurate & reliable information for decision making Prepares accurate & timely compliance reports Supports an effective compliance program Is a key factor in minimization of risk All Rights Reserved 2

3 #10 Outdated Audits and Monitors Problem: They used to make sense, data is still be collected but they are no longer relevant Strategies: Inventory all current audits and monitors Prioritize Know your risk areas Know your past performance All Rights Reserved 3

4 #9 Non-actionable Results Problem: Data is collected but there are no actions that can be taken to impact the area Take time to plan the audit Results must be actionable #8 Ill-Planned Audits Problem: Inquiries undertaken without adequate examination of the methodology Follow the 3 Basic Auditing Principles 1. The question to be answered is meaningful and is clearly, concisely and rationally formulated 2. The data collection process is feasible and provides valid, reliable, discriminatory and actionable data 3. The methodology is logical, appropriate, and passes the group wisdom test Basic Auditing Principle Number 1 The question to be answered is meaningful and is clearly, concisely and rationally formulated Ask yourself these questions to help define the indicator to be measured 1. What do we want to know? 2. Why do we want to know it? 3. What makes it worth the time and energy? 4. Is the question answerable? 5. How will we get the information 6. Will the question, as formulated, give us that information? All Rights Reserved 4

5 A Word about Measurement Tools High impact Simple, understandable, rational and repeatable easy to interpret Shows a trend Clearly defined Is efficient to collect Is timely Measures the process/outcome want to know about Presents data that allows appropriate action to take place Basic Auditing Principle Number 1 Use simple questions that will provide the needed information Make sure that there can be only one right answer (yes/no) Be careful of the not applicable Developing Objective Measures Keep It Simple No lengthy audit tools Be Clear What is the goal? Be Specific Keep the goal in mind Be Concise Less is better Avoid lengthy language All Rights Reserved 5

6 Basic Auditing Principle Number 2 The data collection process is feasible and provides valid, reliable, discriminatory and actionable data For a measurement to be meaningful, it must present data that can be acted upon Valid you can demonstrate that it measures what it is intended to Reliable you get consistent results Discriminatory you can detect differences Feasible burden of measurement acceptable it doesn t take you forever to do Actionable you can do something about it based on the results Basic Auditing Principle Number 2 Specify how measure will be scored and define acceptable parameters Interpretation of results Determine your benchmarks Basic Auditing Principle Number 3 The methodology is logical, appropriate, and passes the group wisdom test Don t create questions in a vacuum! To ensure that the question will make sense to all that will be using it, think carefully about the structure All Rights Reserved 6

7 # 7 No Reporting to the Board Problem: Board needs to be getting information to fulfil their oversight responsibility Board approval of annual audit workplan Board notification if not following audit plan Dashboard Keep Board informed of external trends and plan to address Routine compliance reports to Board #6 Data Discounting Problem: We don t like where the data is pointing so lets just say it s bad Utilizing the 3 Basic Auditing Principles counteracts the ability to discount the data Valid Reliable Discriminatory Journey to Jiseki Stage One Stage Two Stage Three Stage Four The data are wrong. The data are right, but it s not a problem. The data are right, it s a problem, but it s not my problem. The data are right, it s a problem, it s my problem. Institute for Healthcare Improvement All Rights Reserved 7

8 #5 Orphan Results Problem: Something is being monitoring but no one is responsible for paying attention to or acting on the results even though the data provide very helpful information Stakeholder buy in Assign responsibility from the beginning Accountability #4 Lack of Legal Advice Problem: Not structuring the compliance and QAPI committees to afford your hospice needed protection Work with a healthcare attorney in your state to understand the best way to protect your committee(s) work Hard wire in the thought to contact a healthcare attorney when findings suggest potential significant issue PREBILLING!! #3 Key Auditing & Monitoring Areas Overlooked Problem: Overlooked areas especially Medicare Conditions of Participation & Conditions of Coverage Top survey issues Past survey issues Plan of care Pay attention to what OIG is looking at Pay attention to what OIG says Know your MAC edits All Rights Reserved 8

9 #2 Too Many Audits and Monitors Problem: No prioritization of activity so results are meaningless or overwhelming Know and focus on conditions of payment first Prioritize based on risk areas Review any past audit findings to identify trends and any action plans in place Inventory all existing monitors and audits Create and utilize dashboard Past survey deficiencies o What are the ordinary and extraordinary entities up to? What else is Medicare focusing on? What is unique to your hospice? Focus for your compliance activities All Rights Reserved 9

10 #1: No Audits and Monitors At All Problem: Short term savings but very dangerous Leadership engagement Compliance committee directive Board Education Oversight Example: A Care Planning Audit Please refer to Basic Auditing Principles Handout Develop an Auditing and Monitoring Plan How do you decide what to monitor or audit? Who decides? Who is responsible for doing it? How do you document results? How do you report results? What do you do with results? How do you use results for improvement? All Rights Reserved 10

11 Actions of The Prudent Hospice 1. Determine if you are guilty of any of the Top Ten auditing and monitoring problems and work to eliminate 2. Identify your risk areas 3. Develop auditing and monitoring plan focusing on those risk areas 4. Use the Three Basic Auditing Principles as you develop your audit tools and assessment plan To Contact Us Susan Balfour Roseanne Berry Charlene Ross The information enclosed was current at the time it was presented. This presentation is intended to serve as a tool to assist providers and is not intended to grant rights or impose obligations. Although every reasonable effort has been made to assure the accuracy of the information within these pages, the ultimate responsibility for the correct submission of claims and response to any remittance advice lies with the provider of services. All Rights Reserved 11