Protecting the Private Equity Firm Investment with Thorough Compliance and Audit Due Diligence and Placement of a Virtual Compliance Officer

See how Coker helped a private equity firm navigate compliance risks and establish a sustainable compliance program in a new clinical area.

Challenge

A private equity (PE) firm is investing in a new clinical area with little expertise.

Solution

With Coker as their trusted guide, the Target leveraged Coker’s expertise to perform thorough compliance and audit due diligence, identifying significant risk areas. Coker then provided a Virtual Compliance Officer on a remote and fractional basis to establish and manage the ongoing compliance program, ensuring identified risks were addressed and future risks were mitigated.

Approach

  • Step 1Perform Compliance and Audit Due Diligence
    Compliance and audit due diligence is performed, identifying the lack of an established compliance program and audit findings of concerns with modifier -25 usage and incident to billing.
  • Step 2Address Audit Findings and Facilitate Repayment
    Audit findings are used to facilitate the Target’s more robust audit analysis of the errors identified to ensure a complete and timely repayment to payers of the overpayments historically received by the Target.
  • Step 3Provide Targeted Education and Post-Close Support
    Post-transaction close, a Virtual Compliance Officer is placed. The providers receive individualized education on the audit findings. Revenue Cycle staff also receive education in order to ensure claims are processed appropriately.
  • Step 4Establish and Operate Ongoing Compliance Program
    The Virtual Compliance Officer establishes a compliance program, educates providers and staff on the program, and runs the compliance program’s daily operations to ensure areas of concern are addressed moving forward. Providers are audited on an annual basis to ensure training has been operationalized. Audit findings in this clinical area are utilized as a risk potential analysis area in future acquisition due diligence for this PE firm’s portfolio company.
Conclusion

Compliance and audit due diligence are imperative to identify risks to PE firms as they establish and build portfolio companies. Post-close implementation support by placing a Virtual Compliance Officer to oversee compliance activity mitigates risk to the PE firm as it continues to expand. Ongoing provider audits as part of the compliance program help protect the investment by ensuring providers successfully understand key documentation and coding requirements, thereby protecting the PE firm’s investment.

Results At a Glance

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