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Audit-Proofing Your Practice

Module 3: Maryland COMAR Guidance for PRP Services · Lesson 3 of 3

11 min Back to module

Story opener

The audit letter arrives on a Tuesday and asks for twelve charts. Eleven are fine. The twelfth has a plan reviewed eight days late, and that single date costs the agency the whole month of billing for that participant.

Learning objectives

  • Be able to activity is not intervention; describe teaching and response
  • Be able to each note should trace to a plan objective

Lesson

An audit reads your chart without you in the room. Write for that reader.

The chart must independently show: an eligible diagnosis and functional impairment, medical necessity, an active authorized plan, interventions that match plan objectives, participant response, and progress toward measurable goals.

The most common finding is a note that describes activity but not intervention or response. 'Met with participant in community' is not billable content. 'Practiced two-step bus transfer to job site; participant completed transfer with one verbal prompt' is.

Maryland guidance & authority labels

Every statement below is labeled so you know what is binding regulation, what is only proposed, what is professional guidance, and what is our house standard.

  • COMAR — current

    COMAR 10.63.03 requires an authorized service, an individualized rehabilitation plan, documented medical necessity, and staff meeting the qualification standards for the service delivered.

  • COMAR — current

    Rehabilitation plans must be reviewed and updated on the required cycle, with participant involvement documented and signatures dated on or before the service date.

  • COMAR — proposed

    Proposed amendments have periodically tightened staff qualification, supervision-frequency, and telehealth documentation expectations. Track the Maryland Register; do not cite proposed text to a payer as current law.

  • Internal best practice

    Keep a one-page regulation crosswalk in your own words with the citation next to each item, and re-verify it against the current COMAR text every quarter.

Common mistakes

  • Citing a rule from memory or from a colleague's summary.

    Do this instead — Open the current COMAR text and cite the section. Regulations change; memory does not update.

  • Backdating a signature to 'fix' a late review.

    Do this instead — Document the actual date and the reason for the delay. Falsification is a licensure matter, not a paperwork matter.

Practical examples

Practical example

Instead of 'met with participant to discuss goals,' write: 'Reviewed the transportation objective; participant identified the #22 route unassisted and named one back-up plan. Verbal prompt needed once. Next session: practice the transfer at Mondawmin.'

Key takeaways

  • Activity is not intervention; describe teaching and response
  • Each note should trace to a plan objective

Reflection prompts

  1. 1Which part of this lesson describes something you are already doing differently in practice?
  2. 2What would an auditor see in your last five notes that contradicts this standard?

Bring your answers to supervision — the case-study workspace in this module saves written notes to your account.

Knowledge check

4 questions drawn from a bank of 7 · 75% to pass · instant feedback on every answer

1. A colleague does this: Citing a rule from memory or from a colleague's summary. What should they do instead?

2. Which additional point does "Audit-Proofing Your Practice" emphasize?

3. Rehabilitation plans in a PRP must be:

4. Which statement is a key takeaway from "Audit-Proofing Your Practice"?

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