Audits: Audit-proof your files

Q. How can I prepare my team for audits before we get them?
Friday, August 23, 2013

A. The Centers for Medicare & Medicaid Services (CMS) continues to implement new audit contracts and the timeline for responding to the audits seems to get shorter and shorter. Preparing for the potential high-volume of audits coming your way can be discouraging and a headache for your sales and intake teams. Implement a three-step plan to arm yourself with audit-proof patient files before you even submit the claim.

Establish internal quality assurance worksheet

The first step to preparing for potential audits is to establish an internal quality assurance worksheet. Using the local coverage determination (LCD) and the CMS manuals, provide your staff with a list of necessary documentation requirements. Make sure your sales and intake teams understand the regulations and the LCD as they set up new patients or recertify current patients. 

Collect documentation upfront

Do not wait until you are audited to collect your documentation. Collect it when you start the patient on service. If you have all the documentation in-house before you submit a claim, you will be one step ahead when the auditor comes knocking on your door.  

Audit yourself

Not only should your team collect documentation, they should also review the documentation and apply it to the LCD and manuals using your quality assurance worksheet. Perform the internal audit before submitting the claim for reimbursement. Educate your staff about medical necessity and billing requirements, and do not set up a patient until all of the requirements are met. Murphy’s Law states that, “Anything that can go wrong, will go wrong.” This can be applied to Medicare claims, as well: Anything that can be audited, will be audited.

Jillian Longo is a consultant with Harrington Management Group, LLC. Reach her at or 888-833-3478.