By Beth Carpenter
President
Beth Carpenter and Associates
The activities during the due diligence of a home health or hospice license – whether covering single or multiple locations - involves the examination of a number of components in order to assess the efficiency and compliance of an agency. We use a number of proprietary forms to guide the audits in areas such as clinical, regulatory, administrative and environmental considerations. Within each area
are key indicators that the auditors use to measure the findings against industry requirements or best
practice. Our forms are industry-specific and reflect both the federal requirements and state
regulations.
AREAS OF OPERATIONAL REVIEW
- Organizational structure
- Board of Director meeting minutes
- Annual program review
- Required policies and procedures
- Review of internal clinical record audits
- Review of client and caregiver satisfaction surveys
- Confidentiality, security, integrity and storage of records
- Process for patient transfer
- Annual training plans for all disciplines
- Required plans, for example restraints and disaster planning
- Required logs such as infection and client complaints
- Review of average costs of specific areas, for example supplies and mileage as well as visit
average information
- Contract file audits
- Recent surveys by outside organizations such as JC/CHAP/ACHC or state complaint surveys
- Workflow process review for all key processes
- Team ratios, IDG agenda, role of Medical Director/Team Physician for hospices
- All necessary review of the operations of an Inpatient Unit, if applicable, for hospices
- Review of any CAP issues for hospices
- A general market analysis
- Overview of Payroll, Billing and Collection
PERSONNEL ADMINISTRATION AUDIT
- Personnel file components, for example completed application and reference checks per
company policy
- Review of the employment process and license verification process
- Criminal background checks, drug screening and physical examination for employees, as required
- Mandatory training record
- Performance appraisals
- Health files complete and separate
- Ancillary service contract personnel
- Recruitment plans
- Inquiry and processing logs
- Evidence of employee notification of required areas
- Posting of appropriate/required federal posters for personnel
- Review of job descriptions
CLINICAL RECORD REVIEW
- Referral records present and complete
- Plan of Treatment complete and meeting the Medicare guidelines for diagnosis for hospice
- Interim orders present, complete and timely
- Recertification process and requirements followed
- Admission process complete and appropriate
- Client assessment
- Medication profile
- Hospice Aide Instruction Sheet for hospice
- Interdisciplinary Team Group agenda, process and documentation for hospice
- Documentation review for each discipline
- Supervisory visits
- Discharge process
- Revocation process
In addition to the in-office auditing of the materials listed above, members of the audit team will “ride” with staff members to observe their clinical skills and interact with patients and families. Auditors will also question patients on their satisfaction with the agency.
General principles of auditing require us to review a minimum of 10% of the agency's charts including either open or closed cases or a minimum of 10 charts. If you desire a 100% review of all active patients, we will have to extend our time in each agency or bring in more nurses to work on the audit team.
We also conduct interviews with local management to gather their view of who they consider their competition, the strengths and weaknesses of the agency, as well as the opportunities and threats the agency faces locally.
Additionally, field staff is interviewed to gather their thoughts on their initial orientation to the agency, the continuing training they receive, the current supervision level and their understanding of documentation requirements.
The audit is summarized in a final report prepared by Medicare license number and location. The report is standardized by the Audit Team Leader in a format that summarizes each of the sections of the audit as well as including observations and conclusions.
For questions or clarification, please call Beth Carpenter and Associates.
ABOUT THE AUTHOR: Beth Carpenter is the President of Beth Carpenter and Associates, a consulting firm which provides real-world expertise to improve the performance and results of home care, hospice and private duty clients. The firm has earned a reputation as a company that has deep industry experience and one that works closely with its clients to identify solutions that meet their business goals and strategic objectives. Beth can be reached at
bcarpenter@bethcarpenterandassociates.com.
©Copyright 2010 Beth Carpenter and Associates. All rights reserved. No portion of these materials may be reproduced by any means without the advance written permission of the author. |
