#359 - Auditor

One morning, I was sitting in my office, catching up on some paperwork when my receptionist walked into my office looking like she had seen a ghost.  She proceeded to tell me that there was a lady and and man from Medicare in the lobby, and they were there to conduct a surprise audit.

Let me stop for a second and give you some background info.  We had just recently purchased the practice from the original owner who...ummmmm... how do I say this nicely..... was not the best rule follower in the world.  It's not that he was obstinate about not following the rules, it's just that he kinda had the attitude of..."If I'm doing it wrong, someone will tell me eventually and until then, oh well."  Surprisingly, Medicare does not share that same attitude.  So anyway, when the previous owner was enrolled in the Medicare program (1000 years earlier), he just kinda adapted the rules and regs as he saw fit
(read - he didn't do any of the proper paperwork).  Now, I know that ignorance is not an excuse, but when we took over, we just kinda assumed that if he had been practicing for since 1954 without it...we didn't need it.  Turns out that was the wrong assumption.

So anyway, I have these two auditors in my lobby.  My partner was absent from the office that week as it was his week to cover the hospital contract.  So it was me and them...  I took a deep breath and welcomed them in...having no idea that I was doing it all wrong.  They handed me a list of things that they needed to see.  Everything from annual employee performance evaluations from the last 10 years to the documentation reflecting our hand washing policy.  Don't ever let anyone tell you that I don't have a poker face, because I sat there and nodded (while thinking "Oh, shit!) and then I calmly told them that it was going to take me a little while to gather all of the info that they needed because I was the only therapist there that day and I had a full schedule of patients to see in addition to being at their beck and call.  Small office and all...  They said no problem, they would just wait patiently in my office and I could just bring them the items that they needed one at a time.  They assured me that they were not in a hurry and had the rest of the week for my office audit. 

WOW!  Let it also be said, that as a rule, I do not panic.  I exited my office and started to formulate my game plan.  Long story short...I was able to find, in the attic of my building, a box with several inches of dust on it, that read  "Medicare start up documents."  Low and behold, in that box was binder after binder of documents that was an outline of what we needed, but had never been implemented.  I had no employee performance evaluations because none had ever been done.  I had no hand washing procedure because I figured everyone old enough to hold a job and pay taxes knew how to wash their hands.  Anyway, I was able to piece together about 50% of what they wanted, even though it was totally insufficient.

I presented what I could and then waited...and waited...and waited...  They looked at what I had and made lots of notes.  At the end of the day they requested a meeting with me.  Basically in a nutshell they told me that I was doing it wrong.  They said that they did not have to shut me down because I actually had a box with policies, but it was clear that we were not following them.  They had even interviewed my employees and asked them about certain policies.  They gave me a punch list of about a million things that needed to be brought up to regulation.  They gave me one month and told me that they would be back.  I remember looking them straight in the eye and saying to them, "I know that you guys don't know me.  I know that ignorance is not an excuse, but I will tell you that I had no idea that all of these things were required.  I will tell you that in thirty days...they will be in place."  I could tell by their looks that they totally did not believe me.  They had no idea who they were dealing with and they had no idea how much I hate to be unprepared.

Fast forward thirty days.  After much work and revisions (special shout out to Sarah Sue Sue at this point who handled all the typing of our new Policy and Procedure Manual) I was ready.  They came back.  They asked for a page full of stuff.  They got it!  Every single item done to perfection.  Evenly spaced and even the hand washing procedure framed and hung next to every lavatory (in case anyone forgot).  They looked, they nodded, they asked for time to review everything.  At the end of day ( a day where I sweated buckets all day) we convened for a meeting.  They said straight out, "When we left here last month, we thought that there was no way you could bring everything into compliance in one month.  We honestly thought that we were coming to shut you guys down today.  But, you are now in 100% compliance with every rule and regulation."  I, of course, knew that!  :)

I thanked them and they left.  I fully expected them to return in six months to check to be sure I was continuing to wash my hands correctly.  But they didn't.  Six months turned into ten years.  Then one day last summer...they came back.  This time I was ready.  I produced all the info they wanted in about 30 minutes.  The auditor was here for about 2 hours and he complimented me on how well we all knew our hand washing procedure.  After all we had 10 years to practice...

Post post-lesson:  Never assume you know all the rules...find them out for yourself.  Never get lax with time...they always come back.  Never try to skate by with the bare minimum...do your best and you have nothing to worry about!