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Page 12

PPS Alert for Long-Term Care

November 2009


< continued from p. 11

learned from your mistakes. A CAP should include a summary of the review, what caused the error, and how you rectified any immediate effects, such as payment re-

funds or employee disciplinary actions. But most im- portantly, the CAP should outline a plan to reduce

or eliminate the chance of the same mistake happen- ing again. This plan could include conducting additional training and education for relevant staff members as well as drafting a new policy or revising an existing policy or procedure.

the CAP to document its success and further illustrate your dedication to filing claims accurately.

4. Implement an internal compliance program if your facility does not already have one in place. An effective compliance program includes written policies and procedures; a dedicated compliance officer; train- ing and education; effective lines of communication; en- forcement of guidelines; auditing and monitoring; and,

of course, a prompt response and corrective action to po-

tential issues.

Included in this section should be a timeline as well as measurable deliverables (e.g., every billing office employee must undergo claim submission train- ing and pass a knowledge assessment within the next 45 days).

Be sure that employees are aware of and understand the facility’s comprehensive compliance program, be-

cause this knowledge may prevent errors from arising in the first place.

Once the deliverables have been met, the CAP can be updated to reflect the outcome. Finally, the CAP should

include a plan to conduct a follow-up audit on the spe- cific issue that was identified within a reasonable period of time. The purpose of this is to determine whether the CAP was sufficient in addressing and resolving the issue identified.

U l t i m a t e l y , i f y o u c o m e a c r o s s b i l l i n g e r r o r s , y o u s h o u l d

refund any money paid inappropriately or correct the in- formation accordingly, determine what caused the issue and address it, and develop an all-inclusive plan to ensure that it doesn’t happen again.

If an oversight agency reviews your organization, be- ing able to show it a comprehensive CAP demonstrates your organization’s commitment to compliance. The findings of your subsequent audit can also be added to

MDS professor answer key

Below are the answers to the MDS quiz on p. 10:

1. c.

2. d.

3. c.

4. a.

5. b.

6. a.

7. a.

8. b.

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