Preparation and Tips for Reducing Audit Anxiety

You get the letter from your carrier — this group will be auditing your records for the medical nutrition therapy (MNT) services you provided to Medicare beneficiaries over a certain timeframe. Before you start panicking, think through the procedures you have in place that can make the external audit a breeze. The process of auditing and monitoring includes regular evaluations to determine whether your practice’s standards and procedures are current and accurate. It also determines whether you are in compliance with Medicare regulations.

What the auditor will request from your office/practice
If you are audited by an external group such as a Medicare carrier, or even for an internal audit at your facility, you will be provided with instructions on what you should do. Generally you will need to produce information about the MNT service(s) that you provided over a specific timeframe. The auditor will ask for various forms of information. This may include the physician referral form, lab data, your chart note, claims form and other patient-related information such as your client’s Medicare number. If you have systems in place for collecting and storing this type of information, providing details to the auditor should not be difficult or traumatic.

The “Medicare MNT Systems Evaluation” form is a helpful American Dietetic Association (ADA) resource to support having appropriate systems in place to verify that the information you need is always readily available for future audits. Any or all of these components, such as steps to access the Medicare benefit, protocol implementation and claims processing key fields may be reviewed in an audit. This form helps prompt you to consistently consider these items before or as you provide MNT services. Refer to link below for Medicare MNT Systems Evaluation Form.

Conducting self-audits
A vital part of an effective Medicare compliance program is implementing a method, or audit system, to monitor your practice’s procedures, such as patient screening data, MNT coding and documentation. A peer-review self-audit is a means to assess these processes. The self-audit is a cost-effective way to protect against fraud and abuse, and it also is a valuable educational tool for providers to improve their coding and documentation skills.

The self-audit should be performed at minimum once a year. Your audit results will be the guide to how often you perform an audit. Monthly or quarterly would be considered a best practice. To establish a benchmark for measuring future Medicare compliance, RDs should conduct an audit in the first three months after the practice has completed education/training on the compliance issue(s). Although there is no set formula as to how many medical records should be reviewed, the Office of the Inspector General of the Department of Health and Human Services (OIG) recommends a basic guide of two to five medical records per payer or five to 10 medical records per practitioner. 

After checking each chart to determine if the appropriate information and components of care are completed, RDs should summarize the results on paper or in an electronic format. RDs may prefer setting up a spreadsheet file to record this data and track the results over time. If the audit uncovers problems, the RD/group should conduct a focused review more frequently. When audit results reveal areas needing additional attention or reflecting the need for education, these areas should be incorporated into the practice’s training and education program. Based on the peer-reviewed self-audit results, practitioners should set up plans to correct deficiencies or errors that are identified from the self-audit. The action should be taken as soon as possible. The OIG recommends that the action be taken within 60 days of the date the problem is identified.

RDs also should write up their specific procedures for self-audits and describe corrective measures in their practices’ policy and procedure manual. 

Making sure you have systems in place for each step of the Medicare benefit, as well as conducting peer-review self-audits will reduce the anxiety of external audits and enhance the quality MNT services you provide.

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