Even with home health agency’s efforts to comply with Medicare regulations, the looming potential of being identified as an “outlier” by a ZPIC leaves you subject to a full-blown audit. In fact, this may happen for many reasons; a ZPIC audit could use data analysis to detect “outliers” compared to local and national patterns, employee or beneficiary whistle-blowers, or referral from a MAC or other contractors based on the results of a previous audit.
Should your agency receive a ZPIC Audit being prepared is a key step to ensure documentation and billing compliance. Taking a proactive approach is necessary. Learn from our clinical compliance expert, Dee Geray, about the best steps to take to prevent a ZPIC audit:
My Agency is receiving a ZPIC audit, now what?
- Report the ZPIC auditor presence to key parties in your organization.
- Involve legal counsel immediately.
- Take your time in preparing requested documents and request extension as needed.
- Use the full allotted time frame to ensure all documents of the record are provided so both technical and clinical eligibility are evident.
- Include supporting documentation prior to and post review request that support clinical eligibility.
- Submit additional request documents as soon as possible.
- Ensure each packet is prepped at the same time.
- Keep exact copies of any submitted documents.
- Have a central mail repository so no demand letters are missed.
- Review all findings when they arrive. The documents can be lengthy.
- Alter documents that are requested.
- Use this time to identify problems, instead focus on the task at hand.
About The Contributor
Dee Geray, RN, Clinical Consulting Manager
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.