The Role of Monitoring and Auditing
Ongoing compliance monitoring and auditing form a core element of an effective compliance program, allowing organizations to detect and correct problems before they result in significant regulatory exposure or financial harm. Monitoring and auditing are related but distinct activities that serve complementary purposes.
Internal Audits
Internal audits are conducted by an organization's own compliance, internal audit, or HIM staff to evaluate adherence to policies, coding accuracy, documentation practices, and regulatory requirements. Internal audits can be scheduled routinely or triggered by specific risk indicators, such as a spike in claim denials or an employee complaint.
External Audits
External audits are conducted by outside entities, including government contractors such as Recovery Audit Contractors and Unified Program Integrity Contractors, private payers, or independent consulting firms engaged by the organization. External audit findings can result in payment recoupment, corrective action plans, or referral for further investigation if significant compliance concerns are identified.
Monitoring Plans
A comprehensive monitoring plan defines the specific compliance risk areas to be reviewed, the frequency of review, responsible parties, and methodology for each monitoring activity. Risk areas commonly monitored in HIM include coding accuracy, release of information compliance, access log review for inappropriate record access, and documentation timeliness.
Corrective Action
When audits identify deficiencies, organizations must implement corrective action plans addressing root causes, not merely individual instances of non-compliance. Effective corrective actions may include staff retraining, policy revision, system configuration changes, or enhanced monitoring frequency for the affected area until sustained improvement is demonstrated.
Compliance Dashboards and Reporting
Compliance dashboards aggregate key metrics such as audit findings, corrective action status, and training completion rates, providing leadership and the compliance committee with visibility into overall program effectiveness. Regular reporting to organizational leadership and the board ensures compliance remains a visible priority and supports informed resource allocation decisions for ongoing monitoring efforts.