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What is Compliance?
• Continuously monitor data on a periodic, random Compliance is all about doing the right
basis thing: Pay the right amount to the right
• Provide ongoing training to personnel provider for the right beneficiary for
• Perform investigations if a problem is detected QC vs. QA the right reason for the right test.
• Notify providers/clients and reissues reports if QC – refers to the procedures for the measures that must
data/results are negatively impacted be included during each assay run to verify that the
test is working properly. This is a laboratory
function.
QA – refers to the overall program that ensures the final
results reported by the laboratory are correct. QA
activities are performed by staff who are not directly Compliance and Regulatory
Soup
involved with the analysis of clinical samples.
Ingredients:
Coding
Documentation
Medical Necessity
Internal
Auditing & Monitoring
External CT audit types: ABN MCD CPI NPI HEAT RAC CMS
pre-qualification, qualification, study specific & for-cause AKS MCFU CPT OIG HER SCR NGS
Our Role: In 2015: ALJ MCR CSP OMIG HHS SMP HCPCS
Promote an environment of audit preparedness • The team performed approximately 65 internal
AO MLN DOJ OPPS ICD SNF PTAN
Ongoing monitoring of CT study documents audits
Perform laboratory tracer audits • The team participated and prepared for 5 NYS APG NGS DRG PAO IPPS TOB
Perform “mock- audits” of study Inspections and 3 CAP inspections.
CERT MPFS EMR PCS LCD UPIN
Facilitate external audits • The team participated and prepared for 6 external
Encourage an “information sharing” approach with client client audits for clinical trials. CLFS NCCI FCA PQRS LCSC ZPIC
auditor Tips for Successful Audit: CMP NCD FI PSC MAC NCCI
Provide response to audit findings • Respond to the question asked with simple, honest,
Clinical Laboratory NYS Department of Health
Support resolution of audit finding resolution. and complete answers. Evaluation (NYSDH)
• Listen actively and ask for clarification if you are CAP Inspection College of American Pathologists
Clinical Trials sample is a “one time opportunity” to unsure of what is being asked.
capture specific information contained in the specimen only • Don’t rely on memory alone – review the documents AABB inspection American Association for Blood Banks
at that specific time period. yourself. (BB)
• Deferring to and locating the correct person to FDA Inspection US Food and Drug Administration
(Blood Bank)
CLIA CAP ICH E6 GCP GxP answer the question asked within a specified FACT Inspection Foundation for Accreditation
time window is acceptable. (Stem Cell/Blood Bank) of Cellular Therapy
• It takes a village…Assemble and rely on a Team ASHI inspection American Society of Histocompatibility
(HLA Lab) & Immunogenetics