How to Survive an On-Site Audit

How to Survive an On-Site Audit by Elements magazine | pbahealth.com

The day of your on-site pharmacy audit has finally arrived. You’re well prepared, fully informed and organized to a tee. Now, learn what you can do during—and after—the audit to make the process as painless as possible.

Be on time
Arrive before the auditor, and greet them at the door. If you’ve decided to videotape the on-site audit, explain to the auditor that you’re making the tape for record keeping purposes or to train staff for the next on-site audit. If the auditor will not agree to the taping, take detailed notes instead.

Be polite and courteous
Maintain professionalism during the audit. Avoid yelling, anger and sarcasm. If you must question or challenge the on-site auditor, do so calmly and respectfully.

Ask questions before
Be sure to ask questions ahead of time like:

  • Which prescriptions will be audited?
  • Why was your pharmacy selected for audit?
  • Will the auditor utilize extrapolation methods?
  • If so, which methods?

 

Take notes
Even if you’re videotaping, take detailed notes covering every aspect of the audit. Add these to your audit file or box when the process is complete.

Ask questions during
Ask questions that arise during the audit, always taking care to be respectful—never hostile.

Answer questions
You can be honest without volunteering unnecessary information; “yes,” “no,” “I do not remember” and “I do not know” usually will suffice.

Adhere to HIPAA
The Health Insurance Portability and Accountability patient information requires the auditing entity to sign a business associate agreement with the PSAO so the auditor will keep information confidential.

Keep original documents and records with you
Make copies for the auditor so you can study the originals when he’s done. Take notes of which files are produced in case the auditor asks for them again. Never leave the auditor alone with your records, and do not allow them to wander through your store. Limit the auditor’s access to the items that were mentioned in the written notification or with some relationship to the prescriptions being audited.

Schedule an exit meeting
Take this opportunity to learn whether the auditor identified any problems during the on-site audit, and if so get them in writing with a date and signature. Limit the chargebacks that result from the on-site audit by asking the auditor whether any problems can be resolved with supporting documentation or evidence. Be sure to take notes during this meeting.

Take measures after the audit
When your on-site audit concludes, gather any supporting documentation you may have to solve problems that arose during the audit. There may be a specific time frame in which to produce this documentation, so don’t delay. Once you’ve collected your supporting evidence you should:

  • Write a cover letter outlining your supporting evidence
  • Copy any documentation and include it with your letter
  • Send your letter via a method that requires the auditing entity to acknowledge receipt
  • Contact your legal representative if necessary for rebuttal arguments
  • Make copies of all documentation for your file
  • Rebutting and appealing findings

 

A written report should arrive following receipt of your supporting evidence. Follow this report up with written correspondence to the auditing entity that rebuts or appeals theses findings. Document everything. Send everything via a method that requires the auditing entity to acknowledge receipt.

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Elements is written and produced by PBA Health, a buy-side solutions company.

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