Groundhog Day: CMS Issues Best Practice Memo Related to Common Audit Findings

Is it Groundhog Day or does this memo say the same thing as last year? Nope you’re not imagining things – In CMS’ Memo titled “Common Conditions, Improvement Strategies, and Best Practices based on 2013 Program Audit Reviews” that was released on August 27th, CMS outlines again the industry pitfalls and best practices around common areas of noncompliance identified as a result of CMS Program Audits. You may be saying to yourself “some of this looks familiar” well — you’re right.

In fact, it appears that CMS is getting weary of repeating themselves year over year and they’ve included some language with teeth in this most recent memo. CMS makes two key statements in the 2014 memo — the first is that due to the number of repeat findings year over year, it has been determined that Organizations are not using this memo as CMS intended. The second, and more pointed statement is that Conditions noted in one or more memo will be considered “aggravating circumstance” during an audit and this may adversely affect the overall audit score.

So — what does this mean to your Organization? It means that if you haven’t yet done so, now is the time to review each best practice memo provided by CMS and ensure that the recommended process is in place. If not, it’s time to create and implement a corrective action plan for each best practice mentioned by CMS that would apply to your Organization. Remember, CMS understands that Organizations aren’t perfect, but demonstrating that you’re able to identify issues and put a plan in place to remediate those issues is always required.

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