Corporate Compliance Audit Process Checklist

To ensure consistency and efficiency in the audits at WellSpan Health in York, Pennsylvania, Compliance Audit Coordinator Frank Mesaros documented its audit process in a manual and then put it in an electronic form when everyone scattered because of COVID-19 (see story, p. 1).[1] Here’s one of the documents from the audit manual. Contact Mesaros at fmesaros@wellspan.org.

STEP 1: RESEARCH AUDIT TOPIC

DATE COMPLETED

COMMENTS/WORK PLAN REFERENCE

Identify risks from previous internal/external audits or other risk analyses (such as bell curve analysis).

Review source of risk documents.

Identify department contacts.

STEP 2: NOTIFY MANAGEMENT OF THE AUDIT IN PERSON OR VIA CALL

DATE COMPLETED

COMMENTS/WP REF

Send pre-audit survey to manager.

Discuss any issues/concerns with manager.

Schedule date to begin field work.

Address any deficiencies noted in the pre-audit survey (such as lack of a hotline poster).

STEP 3: PERFORM AN OVERVIEW OF DEPARTMENT FUNCTIONS, IF APPLICABLE

DATE COMPLETED

COMMENTS/WP REF

Request relevant policies and procedures.

STEP 4: PREPARE PAPER/ELECTRONIC AUDIT FOLDER, INCLUDING WORKPAPER INDEX

DATE COMPLETED

COMMENTS/WP REF

STEP 5: DETERMINE SCOPE AND SAMPLE SIZE TO REVIEW

DATE COMPLETED

COMMENTS/WP REF

Obtain population of claims for sample selection.

Select sample (describe population and document how sample was selected).

STEP 6: DETERMINE AUDIT CRITERIA (ATTRIBUTES TO BE TESTED) AND DEVELOP AUDIT PROGRAM/SPREADSHEET

DATE COMPLETED

COMMENTS/WP REF

STEP 7: REQUEST AND VIEW RECORDS, BILLING, AND CLAIMS

DATE COMPLETED

COMMENTS/WP REF

Record findings in spreadsheet.

Review findings for trends; group findings into categories.

Document last date of field work (this will be the report date).

STEP 8: HOLD AN EXIT CONFERENCE TO NOTIFY DEPARTMENT MANAGER OF PRELIMINARY FINDINGS

DATE COMPLETED

COMMENTS/WP REF

Allow for department to provide additional supporting documentation, if available.

Revise spreadsheet, if applicable.

STEP 9: WRITE DRAFT REPORT (REFERENCE AUDIT REPORT POLICY)

DATE COMPLETED

COMMENTS/WP REF

Include audit number from work plan in report title.

Send draft report to audit coordinator for review.

After coordinator approves, send draft to director for review and approval.

STEP 10: SEND DRAFT REPORT AND “GUIDANCE FOR MANAGEMENT COMMENTS” TO DEPARTMENT MANAGER

DATE COMPLETED

COMMENTS/WP REF

Allow two weeks for management to respond (diary your calendar).

Review management response for sufficiency.

If responses are sufficient, continue to next step. Else, work with manager to address insufficient or incomplete responses.

STEP 11: WRITE FINAL REPORT

DATE COMPLETED

COMMENTS/WP REF

Include “Compliance Response to Management” comments, if appropriate.

Send report to coordinator for review and approval.

Send report to director for review and approval.

Enter link to final approved report.

LINK:

STEP 12: RELEASE FINAL REPORT, ONCE APPROVED

DATE COMPLETED

COMMENTS/WP REF

Send paper copies to designated managers, VP, president of entity, counsel, etc.

Ensures reports are not easily forwarded on to anyone outside WellSpan

Makes sure the reports do not get lost in email of our senior leaders

Ensure a copy of final report is included in audit work papers.

Send a copy to coordinator for inclusion in the audit binder.

Upload to portal.

Send an email copy of the completed report to compliance department team members that conduct hospital or defense audits.

Prepare audit slides and save to report folder.

STEP 13: SEND POST-AUDIT SURVEY TO MANAGER WITH INSTRUCTIONS TO RETURN TO DIRECTOR

DATE COMPLETED

COMMENTS/WP REF

STEP 14: DETERMINE POST-AUDIT CORRECTIVE ACTIONS TO MONITOR (AUDIT COMMENT FOLLOW-UP)

DATE COMPLETED

COMMENTS/WP REF

Perform testing to ensure corrective actions have been put into place (60 days from report date).

Diary your calendar for this follow-up.

STEP 15: DETERMINE IF/WHEN RE-AUDIT IS REQUIRED. DISCUSS WITH AUDIT COORDINATOR

DATE COMPLETED

COMMENTS/WP REF

Diary your calendar for the follow-up audit.

STEP 16: INCLUDE A COPY OF THIS CHECKLIST IN THE AUDIT WORK PAPERS

DATE COMPLETED

COMMENTS/WP REF

STEP 17

DATE COMPLETED

COMMENTS/WP REF

On a scale of 1-5, with 5 being the best, rate the department on how knowledgeable you feel the staff is on compliance.

1 2 3 4 5

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