This Audit Protocol is designed as the basis for an audit tool to complement analytic audits of a physician’s prescribing characteristics. Most audit methods used by State and Federal authorities rely exclusively on analytics without considering the clinical circumstances of individual patients. This methodology is designed to provide a comprehensive framework based on the universality of generally accepted principles and methods, guidelines and industry best practices with citations to applicable statutes.
Pain Mangement Protocol Development Methodology
This Audit Protocol was developed based on guidance from Federal and State standards, clinicians and experts. It is used to provide a universal framework with defensible criteria that can support or find gaps in provider prescribing of controlled substances.
- Guidance from Federal sources:
- S. Department of Health and Human Services Centers for Medicare and Medicaid (CMS)
- S. Department of Health and Human Services Centers for Disease Control and Prevention (CDC)
- S. Department of Justice Drug Enforcement Agency Office of Diversion Control (DOJ DEA ODC)
- Guidance from Medical Professional Associations Re: Audit Tools
- American Academy of Pain Medicine
- American Health Information Management Association (AHIMA)
- Guidance from the State(s) where the physician is domiciled
- Federation of State Medical Boards
- State Prescription Drug Monitoring Programs (PDMP)
- State Consumer guidance
- State legislative mandates
- Other state Pain Guidance, adopted in other States
- Developed by Clinicians and Experts
- Team Composition:
- Anesthesiologist
- Pharmacist
- Board Certified Orthopedic Surgeon
- Expert witness in medical coding and billing, Medicare and Medicare Fraud, electronic health records, HIPAA Privacy and Security certified by Federal and State Judges and Arbitrators
- Team Composition:
- Team Experience:
- Opioid class action litigation
- Improper prescribing of Opioids in medical malpractice litigation
- Fraud, waste and abuse litigation
- Prior experience of team with Federal contractor audit methods:
- Zone Program Integrity Program Contractor (ZPIC)
- Medicaid Integrity Contractor (Audit MIC)
- National Benefit Integrity Medicare Drug Integrity Contract (NBI MEDIC).
- Unified Program Integrity Contracts (UPICs) effective May 2016
Opioid Prescribing Audit Protocol Key Elements
Audit Protocol Development Methodology
Goals in Reviewing a Pain Management Practice
Audit Protocol : patient record random sample that is statistically projectable, provider interviews
Physician Prescribing Analytics
Examine Prescribing Volume and Days of Supply per Patient
All Providers and key medical specialties
Diagnosis
Initial Patient Intake and Examination
Formulation of Treatment Plan
Pain Management Agreement
Re-Assessment
Objective Measures and Corrective Action
State PDMP Database Checks
Toxicology / Drug Screening
Titration / Weaning
Termination
Appendix A1 – A3 – Pain Screening Tools
Appendix B1– Guidelines
DOJ Diversion Control Division Controlled Substances Act Guidelines
Medical Necessity and the Controlled Substances Act
The Practitioners Manual, Section IV – Record Keeping
The Practitioners Manual, Section V – Valid Prescription Requirements
The Practitioners Manual, Section VI – Opioid Addiction Treatment Programs
Appendix C – State Treatment with Opioid Patient Agreement “Pain Management Contract”
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