The request arrives on an ordinary day. A payer is requesting records; they have initiated an audit. Deadlines immediately matter. Documentation that once seemed easy to locate suddenly becomes difficult to find. Questions arise about authorizations, supporting records, and whether the claims can withstand scrutiny.
An audit does not create problems; it reveals them. It should trigger a process, not a scramble. The question is not if an audit will occur, but when—and whether your ambulatory surgery center (ASC) will be ready.
In a previous article in The Ophthalmic ASC, “10 Steps to Bulletproof Internal Chart Audits,” I presented a practical framework for conducting internal chart audits to identify vulnerabilities. Audit readiness is demonstrated by whether an ASC corrects those vulnerabilities, verifies improvement, and can support its claims when they are tested.
Medicare Part B identifies insufficient documentation, missing documentation, and incorrect coding as leading causes of improper ASC payments.¹ Audit readiness is a continuous process that combines internal review, corrective action, staff education, and external-audit response.²
Identifying Readiness Risk
Internal audit findings should guide readiness efforts. In ophthalmic ASCs, recurring vulnerabilities often involve surgery documentation, medical-necessity support, prior authorizations, modifier usage, and coordination between surgeon-office and facility records. The objective is not to review everything; it is to focus attention on areas where deficiencies could create the greatest compliance, operational, or reimbursement risk.
Prepare the Documentation Like an Auditor
A valuable readiness exercise is assembling the same documentation during an internal audit that an ASC would submit during an external review. The purpose is to determine whether the ASC can efficiently locate, assemble, and produce the documentation needed to support payment.
In many ophthalmic ASCs, the documentation needed to support payment is divided between facility and surgeon’s office record. The ASC may possess the operative report and procedural documentation, whereas medical necessity, testing, and treatment history remain in the office chart. An audit-ready ASC understands those dependencies and establishes processes to obtain supporting records before they are needed. Medicare Part B guidance instructs that billing surgeons who are responding to documentation requests should obtain all supporting documentation necessary to substantiate the billed service, including records maintained elsewhere and records predating the service under review.4
Look for Patterns, Not Isolated Errors
Readiness reviews should evaluate whether documentation, workflows, and responsibilities function consistently across physicians, staff, and locations. Determine whether deficiencies represent isolated events or recurring patterns that suggest broader workflow, training, or system issues.
Individual findings matter, but trends matter more. Repeated deficiencies often reveal operational vulnerabilities that may not be apparent from a single record review. Tracking findings over time can help determine whether corrective actions are working and whether risk is decreasing.
Review the Documentation Like an Auditor
A readiness review should determine whether the documentation can withstand external scrutiny. Medicare Part B identifies insufficient documentation as records that fail to establish the service performed, the level billed, or the medical necessity of the service per payer policy.4 For Medicare services, the auditor’s checklist should also be guided by the applicable Medicare Administrative Contractor (MAC) local coverage determinations (LCDs) and related local coverage articles (LCAs), which often define the documentation elements needed to support coverage, coding, and medical necessity. Findings should identify specific deficiencies, the applicable payer or MAC requirements, and potential consequences rather than simply labeling a record “incomplete.”
Turn Findings Into Action
Audit findings should identify whether a problem is isolated or systemic and whether its source is education, workflow, policy, or technology. Immediate correction may involve claim correction, obtaining supporting documentation, compliance review, evaluation of potential overpayments, or escalation when appropriate. Long-term corrective action should address root causes through policy, workflow, or educational improvements and include clear ownership, deadlines, and follow-up monitoring. Guidance from the Office of Inspector General (OIG) emphasizes not only identifying problems but also addressing and monitoring them after discovery.² Effective readiness programs measure success by preventing recurrence, not merely correcting individual errors.
Readiness Involves the Entire Team
Most audit findings reflect process weaknesses rather than individual mistakes. Authorizations, documentation, coding, and record retrieval often involve multiple people and departments, making audit readiness a shared responsibility. Education should focus on improving processes rather than assigning blame by clarifying what was missing, why it matters, and how the revised workflow should function. Follow-up audits should verify that corrective actions remain effective.
Document the External Audit Response
Audit requests may come from Medicare contractors, commercial payers, or other reviewers, but the readiness principles remain the same: Understand the scope, gather supporting documentation, meet deadlines, and maintain a complete submission record. Every ASC should maintain a written audit-response process with clearly assigned responsibilities.
For Medicare Additional Documentation Requests, Medicare Part B recommends including a copy of the request letter with the submission.5 A response process should be established before it is needed and should never depend on institutional memory or informal workflows.
Audit Readiness Is the Goal
The most audit-ready ASCs are prepared by building processes that generate complete, accurate, and defensible records every day. Internal audits identify vulnerabilities, corrective actions reduce risk, and response plans create consistency. Together, those efforts transform audit readiness from a compliance project into an organizational capability. An audit request may still interrupt the day—but it should never throw the center into chaos.
Audit Readiness in Action
During a routine internal audit of cataract surgery claims, an ASC identifies a case missing documentation supporting the commercial payer prior authorization. Expanding the review reveals similar gaps in several cases processed during a recent staffing transition. As the ASC assembles the documentation package, another area of improvement is discovered: Obtaining medical-necessity records from the surgeon’s office is inconsistent because responsibilities and retrieval procedures are unclear. The ASC assigns ownership, standardizes record-request procedures, and adds a pre-bill verification step to confirm that required documentation is available before claims are submitted. A follow-up review several weeks later finds no recurring deficiencies and confirms that surgeon-office records can be obtained quickly and consistently.
Three months later, the ASC receives a commercial payer cataract audit request. The request is logged, deadlines are tracked, and the required documentation—including surgeon-office records, authorization documentation, and operative reports—is assembled and submitted on time.
ASC Audit-Readiness Checklist Before an Audit Request Arrives
- Assign responsibility for audit-readiness activities.
- Maintain a written audit-response policy.
- Review denial trends, audit findings, and recurring deficiencies.
- Identify high-risk and high-volume services.
- Maintain current payer policies and Medicare guidance.
- Add applicable MAC LCD/LCA requirements to audit checklists.
- Verify access to surgeon-office and other supporting documentation.
- Conduct routine chart, documentation, and claim reviews.
- Document internal corrective actions and staff education.
- Perform follow-up reviews to verify improvement.
- Periodically test the audit-response process
When a Request Is Received
The steps here are to determine the scope of the request; record receipt date; identify requesting contractor and type of audit; confirm claims, services, and dates under review; determine submission deadlines; notify designated response personnel; create a request-tracking log; and assign a communication coordinator.
Before Records Are Submitted
- Obtain all supporting documentation, including surgeon office records when applicable.
- Confirm payer and MAC documentation requirements met.
- Confirm patient identifiers on every page, including same-name safeguards.
- Confirm all entries include complete dates, including year.
- Verify legible or secure signatures identify the responsible physician.
- Confirm history, physical, and discharge records are included when applicable.
- Match documentation to each claim under review.
- Include required authorization documentation.
- Verify records are legible, organized, and free of inappropriate remarks.
- Confirm corrections follow policy and avoid omissions, erasures, or missing pages.
- Secure paper records and confirm pages are complete, labeled, and organized.
- Confirm allergies, adverse reactions, prescriptions, and refills are documented.
- Verify orders, test results, and physician review are documented.
- Confirm diagnoses, findings, and treatment plans are consistent.
- Confirm surgical consents are signed, dated, and witnessed, and specify laterality when applicable.
- Confirm follow-up plans and unresolved problems are addressed.
- Confirm clinical staff, patient-care calls, and approved abbreviations are documented appropriately.
- Retain a copy of the submission and proof of delivery.
After the Review
- Track additional requests and deadlines.
- Evaluate findings promptly.
- Determine whether issues are isolated or systemic.
- Evaluate repayment, correction, or appeal needs.
- Implement corrective-action plans.
- Provide targeted education.
- Conduct follow-up monitoring to confirm improvement.
References
1. Centers for Medicare and Medicaid Services. Ambulatory surgical centers. Accessed July 21, 2026. https://www.cms.gov/training-education/medicare-learning-networkr-mln/compliance/medicare-provider-compliance-tips/ambulatory-surgical-centers
2. US Department of Health and Human Services Office of Inspector General. General compliance program guidance. Accessed July 21, 2026. https://oig.hhs.gov/compliance/general-compliance-program-guidance/
3. American Academy of Ophthalmology. How to perform internal chart audits in 10 steps. Published November 11, 2022. Updated July 2026. Accessed July 21, 2026. https://www.aao.org/practice-management/news-detail/how-perform-internal-chart-audits-10-steps
4. Centers for Medicare and Medicaid Services. Complying with medical record documentation requirements. Published December 2024. Accessed July 21, 2026. https://www.cms.gov/files/mln909160-complying-with-medical-record-documentation-requirements.pdf
5. Centers for Medicare and Medicaid Services. Additional documentation request. Updated March 4, 2026. Accessed July 21, 2026. https://www.cms.gov/data-research/monitoring-programs/medicare-fee-service-compliance-programs/medical-review-education/additional-documentation-request
