Audits and investigations are stressful events either with or without prior notice. Medical staff should be prepared for an unannounced visit. First Healthcare Compliance provides a sample policy that assists clients in preparing the front office. Here are some recommendations to ensure that proper steps are taken:
- Immediately contact your supervisor, manager and/or Compliance Officer or CEO.
- Find out the government representative’s name, title, department, badge or identification number. If possible, obtain a business card.
- Find out as much information as possible regarding the documents being requested.
- It is reasonable to respond to an unannounced visit from a government representative by requesting to schedule to speak with the representative at a later date.
- Employees are free to decide whether or not to speak to the representative and are encouraged to take notes regarding any encounters made with the representatives.
- If employees decide to speak to the representative, they are entitled to have an attorney present, either one provided by the entity, or one of their own choosing at their own expense. Any questions asked by the representative should be answered completely and accurately.
- Be polite and helpful to the government representatives, but do not grant access for a search without guidance from your supervisor or manager.
- Any searches requested may not be conducted without a legally valid search warrant. Employees should request time to contact the attorney to determine whether the warrant is valid.
- Employees must be aware that no documents sought in the investigation are to be destroyed or altered in any way.
Most importantly, do not panic. Having a plan in place can make a big difference in the initial reaction of the staff and the outcome. Remaining calm can set the tone for the entire auditing process.
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