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Clinics and practices know it is important to perform routine internal monitoring and auditing as part of an effective compliance program and as a good business process. Most administrators' duties involve ongoing reviews of coding, billing, and other practice data. Rather than believe that external resources must be used for coding and billing compliance audits, this article advocates that maintaining supporting documentation of routine variance analysis or potential issue resolution not only enhances the practice's compliance efforts but also provides the groundwork to implement effective changes in a cost-saving manner.
KEY WORDS: Compliance; monitoring and auditing; change management; internal resources.
CHANGE MANAGEMENT
Change management is a formal process by which change is carried out and, therefore, sometimes is thought of as making change more difficult by adding "red tape." Large healthcare organizations benefit from a properly implemented change management process by establishing various controls over what changes are made at what time. Before any changes are implemented, the organization's change management process should require the following:
* An evaluation of all proposed changes for benefits and risks, and consideration of all potential impacts;
* A preapproved prioritizing method for any changes so that limited resources are allocated to those changes that produce the greatest benefit based on the organization's need;
* A thorough testing procedure for all changes prior to deployment; and
* A documentation management archive that reflects any changes and the effects they had on the organization.1
Smaller healthcare systems such as clinics and physician practices may employ more efficient and quicker change management processes when they have effective internal monitoring and auditing processes in place. These systems are effective when internal monitoring and auditing follow accepted evaluation standards that streamline the change process and reduce the risk associated with making changes. Generally, these changes apply to routine processes that involve minimal risks when implemented.
In clinics and physician practices, an administrator often has been preapproved to implement routine changes to existing processes without receiving special permission from a Governing Committee or Board of Directors. For example, an administrator's routine monitoring of a financial report shows an unusual variance in the reimbursement of an established CPT code. The administrator has approval to review the variance and initiate any required changes to resolve...