When health care providers repeatedly fail to reach compliance with the Office of the Inspector General’s (OIG) guidelines, the OIG will issue them a Corporate Integrity Agreement (CIA). Under the CIA process, organizations enter into a mandatory agreement to improve their practices over a five-year time frame with outlined compliance guidelines set forth by the OIG. Failure to comply with these guidelines can result in breach and default provisions that allow OIG to enforce certain financial penalties on the organization and exclusion from the participation in Medicare, Medicaid, or other Federal health care programs.
My very first encounter with this scenario was during my time working in a hospice management role. The corporate organization that acquired our hospice was under a CIA and had to focus on continually improving their practices over the course of five years. Though the CIA didn’t involve our business line of the organization, we were held to the same compliance standards. Shortly after acquisition, the organization’s corporate compliance team implemented annual mock survey audits (mock survey). The mock survey evaluated their business operations as well as their clinical compliance and quality of care practices. The mock survey provided an amazing learning opportunity for all hospice staff and enhanced the compliance in both the business and clinical operations.
It’s highly recommended that every agency conducts periodic internal mock survey as part of their quality assessment and improvement process on an annual basis. When developing a mock survey process, consider the following:
- What is the purpose of a mock survey? Below are several reasons mock surveys are typically performed:
- Prepare for a state or accrediting body survey
- Validation of quality improvement processes
- Review of clinical documentation and quality of care
- Review of billing compliance
- Evaluate business operations- HR, payroll, contracts
- Conduct a financial process review including accounts payable and receivable
- Educate staff on best practices of internal processes to reduce time of future survey audits
- Who will be conducting the mock survey?
As we work day-to-day in an organization, we become familiar with the process and sometimes develop “work-arounds” to get the job done faster. Internal mock surveys are an option to remedy this. However, it’s extremely beneficial to bring in an outside perspective to receive a comprehensive and unbiased analysis of processes. Those outside “eyes” could include regional leaders, compliance or quality department members, or a contracted agency.
- How often and how long will the mock survey take?
The state operations manual provides guidance to their surveyors about how large of a record sample to select based on census. If wanting to accomplish all that is listed in the first point, it may take longer to complete.
- What tool will you use for the reviews?
The development of a standardized tool for your organization that has weighted categories and a “pass” percentage is key. A tool will not only let the agency know what they are going to be evaluated on but will also show where areas of improvement are needed within processes and departments.
Even without the influence of CIAs, agencies will find that conducting mock survey audits will save them significant financial and compliance issues in the long run. If organizations find that they do not have the proper resources to conduct internal mock survey audits, an outside agency like McBee can also visit and perform the internal survey audit processes. However you choose to conduct the mock process, make sure to develop a thorough plan and put it into action. Please reach out to McBee for any questions regarding mock survey audits and to learn more about our custom compliance solutions.
About The Contributor
Dee Geray, RN, Clinical Consulting Manager – Post Acute, McBee
Dee Geray, RN, is a Clinical Consulting Manager for post acute solutions at McBee. Dee works with home health and hospice providers nationwide to perform Medicare compliance reviews and establish internal audit plans.
