Below are some common deficiencies that were noted in state reviews and audits conducted over the past several years:

1. Inadequate documentation and or lack of Standardize documentation across services providers.

Solution: Standardize documentation across service providers. The standardized forms should include assessments, treatment plans, progress notes, daily and/or weekly logs, etc. Implement appropriate oversight procedures to ensure that all services are performed, documented, billed and accounted for in compliance with applicable requirements. Many organizations are moving to electronic patient records which automate the process and includes built in controls to ensure that the proper information is obtained.

2. Performance of services prior to obtaining authorization or approval of service from agency.
3. Non-compliance with Medicaid and Medicare billing procedures, authorizations, etc. which results in loss of revenue or delay in collection.
4. Excessive salaries not reimbursable under state contracts.
5. Lack of support or oversight for Executive Compensation.

As a best practice all contracts and agreements should be reviewed and the compliance requirements be understood completely before entering into an agreement. Be sure that the staff working on the contract understand the requirements and are able to answer questions if interviewed by a state auditor.

If you are uncertain of the compliance requirements of the impact of an agreement, contact your CPA and or attorney to assist you in understanding the requirements before you enter into a contract.

Stop by our table #41 at the Providers Council on November 6th for the solutions to the rest of these problems.