As hospitals face more scrutiny from the federal government, it’s a good idea for them to audit or assess their compliance learned a group of finance managers Wednesday during an education session offered by the Maine chapter of the Healthcare Financial Management Association.
Hospitals claiming a provider-based status for inpatient and outpatient facilities have come under the scrutiny of the Office of Inspector General and the Centers for Medicare & Medicaid Services in recent years. While the intensity of that scrutiny may soften in 2012, the federal focus on stamping out fraud and belt tightening isn’t going away, so it is better to be ahead of potential problems, said the session leader, Lawrence Vernaglia, a partner in Boston-based law office, Foley & Lardner, where he is the chair of the firm’s healthcare industry team.
Hospitals can choose from three types of audits or assessments, Vernaglia said, each with varying degrees of intensity and expense:
• Foundational – This is the least expensive review a hospital can do, Vernaglia said. It is backward looking, meaning it assesses whether the hospital put the right process in place at the onset rather than determining whether the hospital is in compliance currently. This type of audit is best for services that began after 2002.
• Focused – This is designed to look at high-risk areas and to find problems and correct them, Vernaglia said. It will determine if controls are in place but won’t determine absolutely if the hospital is in compliance.
• Comprehensive – This is the “clean bill of health” assessment, said Vernaglia. It determines if the hospital is currently in compliance.
Which assessment a hospital chooses depends on the facility – where it is located, what it perceives its risks to be and what staff resources are available to conduct an assessment.
If problems are found during an assessment, the hardest issues will be deciding whether or not to correct those that are not directly payment related. “Soft disclosures are well received and haven’t converted into overpayment witch hunts,” Vernaglia said.
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