GETTING THE MOST VALUE FROM AN INTERNAL REVIEW
Periodic audits of the charge description master are a key piece of an organization’s compliance
program. But they can do more than verify compliance—they can help improve the business.
By John Richey, MBA, RHIA
THE CENTERS FOR Medicare and Medicaid Services requires
that all healthcare entities develop and implement a compliance program. One of the key components of a compliance program is periodic charge description master (CDM) auditing.
Reviewing for accuracy is the most important part of an audit, but value-added auditing is more than just a review. Value-added auditing is a systematic, disciplined approach to evaluate
and improve the effectiveness of risk management, control, and
governance processes. 1
Value-added auditing has a focus and a purpose, the results
of which yield information that is actionable; facilitate education and communication among stakeholders; and enhance an
organization’s overall compliance, giving it a better handle on
its financial operations. Therefore, for many practitioners, this
phrase describes audit work that helps management improve
the business, rather than assignments that simply verify compliance with policies and procedures. 2
Planning and conducting an internal audit can be broken out
into 13 steps, the first seven of which—from defining the goals
to evaluating the results—are summarized below.
Successful audits do not just happen. Careful consideration
should be given to the following factors to make certain that the
audit will yield the best results for the organization:
x Goal: What is the overall goal of the CDM audit? The main
goal of any CDM audit is to validate accuracy to support
compliance and the revenue cycle. It is possible that there
could be additional goals, such as to yield information to
support staff education and training.
x Scope: Is the audit to be broad in scope, looking at the en-
tire CDM and every field within it? Or is the audit to be tar-
geted or limited, for example to just certain fields within
the CDM, or to the CDM items in one specific department,
or to high-volume, high-risk procedures and services? The
broader the scope, the more resources required to com-
plete the audit.
x Frequency: How often will audits occur? The entire CDM
should be reviewed annually. Targeted CDM audits
should occur more frequently, such as the CDM of a newly
opened department or service, which could contain doz-
ens or even hundreds of new charge items.
x Budget and resources: What funds are available to sup-
port the audit? Has the department or organization bud-
geted sufficiently to assure successful completion of the
auditing effort? As mentioned earlier, the broader the
scope of the audit, the more resources required to com-
plete the audit.
x Staff: How many staff will be required to support ongoing
auditing? What are the required education, credentials,
and skill sets for the staff?
x Space: Is adequate work space available for staff to per-
form their duties? Do any modifications need to be made
to accommodate their needs? Is there adequate lighting,