Common Compliance Monitoring Pitfalls

In previous blog posts we have covered what a compliance program is and we took a look at how pieces of the OIG’s General Compliance Program Guidance give direct guidance on performing monthly compliance checks within your compliance program. In this post we would like to highlight some common compliance monitoring pitfalls that we have encountered, so that you can remain vigilant regarding your compliance monitoring procedures.

• Not Verifying Possible Matches: The OIG recommends having an audit screening process in place to ensure screening of employees and other relevant individuals is being conducted at least monthly. Based on the OIG’s recommendation, when presented with a possible match from a program like EPStaffCheck, protocol should be to further verify the possible match. Sometimes, that verification process can be as simple as looking at a DOB or a full name and ruling out the possible match based on the data you have available. Other times, you may need to visit the sanctioning agency’s website or reach out to their email contact in order to verify a possible match with an SSN to complete the verification process.
• Running Out of Date Batch Files: This pitfall is twofold. First, it is a necessity that the batch files you are checking each month for compliance are up to date and reflect your current roster of employees/vendors/etc. Second, within a program like EPStaffCheck where you can set your files to automatically run on a certain date each month, it’s important to ensure that you’re only running the files that you need to run to avoid unnecessary usage on your account.
• Report Retention: When getting audited, the last thing anyone wants to do is be in a panic because a particular report cannot be found. Have a designated location for your compliance checks, both monthly and individuals, and be sure reports are being named and organized in a way that everything is easy to locate when needed.
• Not Searching all the Correct Sources: According to Section 6501 of the Affordable Care Act, if an individual or entity is sanctioned in one state, they are considered sanctioned in all states. Searching only a single-state Medicaid opens you to unnecessary risk, since you would have no knowledge if an individual was previously sanctioned in another state. Luckily, all available state Medicaid exclusion databases now come standard with EPStaffCheck to help ensure you’re covered in that department. However, some states and contracts require other non-standard databases be checked in addition to the OIG recommendations. Please be sure you’re checking every source needed to be positive you and your organization are prepared when an audit comes.

Improve Your Compliance Monitoring Program

If you discover that your compliance monitoring program has stumbled into any of these pitfalls, the good news is that they are all easily fixable and they are also easy to avoid in the future. If you are currently an EPStaffCheck client and wish to ensure the program is doing the most for your compliance program, please don’t hesitate to reach out to our helpdesk at assurancesupport@valenzhealth.com with any questions you might have. And if you aren’t currently an EPStaffCheck client, explore the ways in which our compliance management solutions can improve your compliance monitoring program.