Understanding Periodic or New Employee Practice Compliance Audits

Perform and Improve as Needed

By Patricia Trites MPA, CHBC; with Staff Reporters 

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There are several types of compliance audits that a medical practice, clinic or healthcare organization might need to perform. The starting point, discussed elsewhere on this ME-P, is to obtain a baseline audit. The next step is periodic audits or reviews that are performed after information is obtained from the baseline audit.

Periodic Audits

Periodic audits are performed on an on-going basis. Depending on the volume of billing, these may occur weekly for a large multi-specialty ambulatory clinic to quarterly for a small medical practice. These periodic audits can be random or scheduled. Sometimes in the process of seeing how things run, a surprise review can be informative to staff and practitioners.

New Employee Audits

New employees require regular training and reviews until there is confidence in their capabilities. Background checks are often helpful to find out whether there are any potential conflicts. In hospitals, health plan offices, surgery centers, and other regulated facilities, background checks are a normal part of the credentialing process. This process typically includes Medicare violations, which would show up on the National Practitioner Data Bank report. However, independent medical practices do not have access to this type of information and may have to rely on other organizations to obtain the information. The OIG and the General Services Administration both maintain a database of excluded persons and entities that can be accessed through the Internet. As part of the organization’s initial and periodic audits, queries of these two databases should be performed for all employees and independent contractors (like locum tenens physicians). Failure to do so can put the practice at risk of large civil money penalties ($10,000 for each occurrence) and liability for refunds of all claims the excluded individual had part in providing or billing.

Assessment

Additional audits can be performed whenever new employees are added, or if there are complaints or issues that arise in the course of business; prn.

Conclusion

And so, your thoughts and comments on this Medical Executive-Post are appreciated? What interesting, informative or strange tidbits have you uncovered in your auditing processes?

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Locum Tenens Medical Practitioners

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Employment Considerations of a Nomadic Lifestyle

By Dr. David Edward Marcinko; MBA, CMP™

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Locum Tenens [LT] is an alternative to full-time employment for most medical specialties. And, although having never personally used this business model myself [my past work history does include moonlighting, acting as an assistant surgeon, litigation support duties, and/or weekend / after-hours employment], this business model is increasingly attractive to many doctors.

Addressing the Physician Shortage

It is well known that the physician shortage is especially acute in rural America where LT recruiting firms do at least 60% of their business. For example, the National Rural Health Association [NRHA] and the federal Office of Rural Health Policy [ORHP] reports that roughly 25 percent of the U.S. population lives in rural America, but only 10 percent of US physicians practice in these areas. There are 2,157 Health Professional Shortage Areas [HPSA’s] in frontier areas of all states and US territories; compared to 910 in urban areas.

Benefits and Disadvantages

Younger physicians seem to enjoy the travel and excitement of the LT model, while mature physicians like to practice at their leisure. Of course, the lack of a permanent office presence, with its potential equity build-up and little community involvement, may be considered drawbacks of the LT business model

Employment Factors

LT employment factors to consider include third-party employment firm reputation, malpractice insurance, credentialing, travel and relocation expenses [which are negotiable].  

Salary Considerations

A recent survey by LocumTenens.com revealed the following salary considerations:

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Assessment

Moreover, a LT firm typically will not cover taxes. 

Conclusion

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