How to Prepare Your Time Study Program for a CMS Audit
Audits.
That word shoots fear through most CFOs and financial administrators. As we recently reported, the Centers for Medicare and Medicaid Services (CMS) has begun zeroing in on time studies. That means more organizations are having to show their work to their Medicare Administration Coordinators (MACs). For our colleagues that work in Certified Transplant Centers, there is a plan to give their cost reports additional scrutiny in 2025.
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If your system gets audited, the audit is likely to run as smoothly as your time study program. So, what’s involved in an audit and, more importantly, are you ready?
What to expect in an audit
Time studies provide the evidence for Medicare reimbursement submitted in the annual cost report. You’re required to have staff and providers complete a time study for one week of every month (or at least 2 weeks per quarter), with a specific cadence.
They may feel like a nuisance. And, if you’re still using manual processes, they’re time and labor intensive. That makes it easy to let time studies fall through the cracks or have incomplete data as the staff responsible for following through gets pulled into competing priorities.
But when an audit does roll around, you could be at risk of non-compliance and miss out on millions of dollars in reimbursement. MACs could ask you to produce time study data from the past year or from many years before, depending on the time period being audited.
“It’s amazing how you think you’re doing the right thing until someone asks you to show your work,” said Derek Ginos, Senior Director of Transplant and Surgery at Intermountain Health. “When it comes to preparation, the other thing to remember is that it is years in the making. … You’re looking backward in time. The time to prepare for an audit was two years ago, for what they want to look at now.”
What happens if you’re not prepared
Without accurate reporting and data dating back possibly years, CMS could exclude entire weeks or years’ worth of hours from its reimbursable time.
Ginos recently spoke at our webinar Time Studies Gone Bad, sharing times he worked with organizations who underwent audits. One organization had to throw out incomplete data, affecting the organization’s total reimbursement.
“That’s actual information and time that should be counted, but we were not able to,” he said.
Time studies underpin several critical components in the annual Medicare Cost Report (MCR). Capturing physician’s Part A time (e.g., administrative, supervision, teaching, and on-call availability) has a dramatic impact on your hospitals wage calculations that could result in millions of additional reimbursement dollars.
How to prepare
The best way to prepare for an audit is to have a clear process for completing and storing time studies. If you’re lacking that, now is the time to rethink your approach and take a snapshot of your current time study logs.
Accurate information. Provider time can be verified with appointment calendars and the electronic patient record. Using a program that prefills time studies for the provider can improve the chances of completion and boost accuracy.
Real-time data collection. Reduce recall bias by having participants complete the time study during the collection period. And have attestations completed within a reasonable end of the time study period. Automated reminders and easy-to-complete forms help ensure timely reporting.
Data retention. Whether spreadsheets, internal software builds, or a third-party solution, keep your records for years. Using a solution that not only stores your data, but allows you to recall it in a format friendly to auditors can save you and the auditor time.
Time Study is a user-friendly platform dedicated to helping organizations efficiently and accurately complete time studies – even engaging physicians who are notoriously resistant to completing time studies! Our new Audit Center allows users to randomly select time studies for the auditor. Time Study provides the data in a report that’s easy for the auditor to use, reducing friction in the audit process.
If you are interested in learning how we can assist your organization, please use the Contact Us form or email us at info@timestudy.com.
Resources
Building Audit-Ready Time Study Programs (Vol. 5, July 2024)
HFMA Webinar Transcript: Time Studies Gone Bad (September 2024)
HFMA On-Demand Webinar: Time Studies Gone Bad (July 11, 2024, membership required)
