Audit Subject |
Purpose |
Scope |
Lead Person Responsible |
Department |
Projected Timing |
---|---|---|---|---|---|
Medical Necessity of Diagnostic CT and MRI |
To determine compliance with the Centers for Medicare & Medicaid Services guidelines, including physician order, place of service, prior authorization, documentation requirements, specificity of exam, etc. |
Small physician practice may be 100% prospective review, with large organizations at 10% prospective review |
[name] |
Compliance |
1st quarter |
Exclusion Review of Employees, Contractors, Vendors |
To validate that exclusion review is being performed at hire and every 30 days on physicians, employees, contractors, and vendors |
100% review of exclusion monitoring reports for past 12 months; validate a random sample of exclusion reviews reported |
[name] |
Compliance |
1st quarter |
Evaluation & Management (E/M) Documentation & Coding |
To determine compliance with E/M coding guidelines. |
Retrospective review of medical records with date of service January 1–March 31, 20xx Statistically valid random sample |
[name] |
Compliance |
2nd quarter |
Physician Contract Review |
To assess compliance with Stark and/or Anti-Kickback Statute, assess compliance with terms of contract, and review physician compensation |
Small physician practice—all contracts. Large organization—random sample |
[name] |
Compliance and legal |
3rd quarter |
HIPAA Privacy & Security Measures Implemented for Telehealth |
To determine whether provider is using approved telehealth platform, whether a business associate agreement exists, whether informed consent for telemedicine was obtained from the patient, whether a system for monitoring communications containing electronic protected health information (ePHI) has been implemented, and whether only authorized users have access to ePHI |
Statistically valid random sample |
[name] |
Privacy and Compliance |
4th Quarter |
Sample Compliance Program Audit Plan
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