By Brian King, RN, M.Ed CMS Audit Specialist for On Lok PACEpartners All audits present challenges for a PACE organization. An experienced and knowledgeable consultant can reduce team stress, focus team efforts, and guide teams through the complex steps of a CMS audit. As a former CMS PACE clinical auditor, and current member of the On Lok PACEpartners team, I have gained deep knowledge of the audit process, and used my expertise most recently to support a PACE organization through a fully remote audit, utilizing the 2023 protocol guidelines. Our client was a mature PACE program that had not been audited since before COVID and CMS's transition to the fully remote model. Our objective was to review medical records and provide guidance on pre-audit documents, universe submission, audit field work responses, and post-field work document completion. My work initially focused on the completion and submission of universes to ensure the data was accurate and on point—an important opportunity to make a positive impression on the CMS audit team. Next, we focused on training staff to successfully respond to the audit team’s questions. In a fully remote audit, all element (personnel, SDAG and provision of services) auditors review their respective records or case files and submit questions during the first week of field work. For a PACE organization’s staff, this phase can be especially stressful. Understanding current federal regulations is key to responding effectively to auditor questions; I understood the potential non-complaint issues the audit team was exploring and assisted staff in providing answers that minimized additional questions. All clinical root cause analyses for this client were completed prior to the field exit conference. And as overwhelming as audit work can be on staff, the post-field work was even more labor-intensive. CMS required five clinical impact analyses, each entailing an 8-month record review for 100 participants. On Lok PACEpartners guided the team to achieve CMS compliance, providing strategies and assistance to efficiently complete this final phase—a process that further helped the organization understand its opportunities for improvement. Find out how On Lok PACEpartners can help you prepare for a successful audit. Call 855-875-7223 or email sanford.rodgers@onlok.org
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