The sixth element of an effective compliance program is ongoing auditing and monitoring activities. While auditing typically involves the concurrent or retrospective review of identified risk areas, monitoring is about the day-to-day activities and processes we use to make sure we are compliant. The OIG devotes much more ink to auditing in their Compliance Guidance, but it is the initial monitoring activities that produce good audit results.
Monitor transitive verb – to watch, observe, listen to, or check (something) for a special purpose over a period of time (Merriam-Webster Digital Dictionary)
A few examples of monitoring activities:
- Verifying employees, contractors and physicians against the OIG Exclusion List (physicians are frequently overlooked)
- Confirming appropriate signatures, dates and documentation prior to billing for services
- Verifying that patient visits are scheduled appropriately and according to the plan of care
- Ensuring appropriate staffing levels to meet the needs of the patient population
Of course, these activities can later be audited but let’s look at the monitoring process. Notice the term process.
Process noun – a series of actions that produce something or that lead to a particular result (Merriam-Webster Digital Dictionary)
As compliance professionals, we are looking for a particular result from our monitoring activities. To make sure our results are consistent, we need to ensure our processes are consistent. In other words, processes should be written, especially those that relate to monitoring activities. Belief that a process was in place is not a good defense, and “informal” or “unwritten” processes create unnecessary risk.
For additional Resources, check out these websites:
- OIG Compliance Program, Guidance for Hospices
- OIG Compliance Program, Guidance for Home Health Agencies
Prepare. Reinforce. Go Further.
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Contact us for the necessary expertise, resources and tools to improve and maintain compliance.