Step 3: Although CMS allows for identifying and quantifying a potential overpayment to occur after a reasonably diligent investigation, providers should be prepared to take no more than six months to complete the investigative process.
Step 4: Providers should maintain records that accurately document their reasonably diligent efforts to demonstrate their compliance with the final rule.
Step 5: Providers should be prepared to look back six years when identifying potential overpayments.
Step 6: Providers should schedule regular proactive auditing of charts to maintain “reasonable diligence.”
Practices should review the Final Rule. It’s important to look at any existing business practice to mitigate risks that may be enforced by this new rule. For assistance with proactive and retroactive self-audits, contact the ACR healthcare auditors at [email protected] to set up a session in your area.
