Management Tips

What will the URAC reviewers find when they pull a random sample of your employees' personnel files? What should they find?

The URAC standards are rife with requirements that are likely to be evidenced in your personnel files. Because these standards are scattered throughout the Core module, it may not be immediately apparent what a URAC applicant should have in its personnel files.

Here's a short list, taken from an actual URAC onsite review agenda one of our clients just received from URAC, rearranged for clarity's sake:

Evidence of Training

• Conflict of Interest Training
• Education on URAC Standards
• Continuing Education
• Orientation to job
• Staff Confidentiality Statements
• Regulatory Training
• Fraud & Abuse Training

Other documentary requirements

• Annual Performance Review Process
• Job description/qualification evaluation

Special requirements for clinical staff

• Scope of Practice Attestations
• License verification
• Certification verification

Particularly if your organization is a first-time applicant, you may be realizing that your personnel files don't have all these documents. What do you do now?

We recommend this four-step approach:

1. Conduct a thorough initial assessment. How bad is it? Take a random sample of your employee files and run down the above list for each one. Using this list to perform a gap analysis that will let you know the difference between what you have and what you need to have by the time the reviewers arrive.
2. Look for alternative sources of information. Now that you know what you need, find out whether you have that information, but not in the personnel files. For example, if your company has a centralized training tracking function, you may be able to take care of demonstrating compliance with all or most of the training documentation requirements through that tracking function.
3. Make a plan. With those items that are neither in the personnel files nor in a centralized function, you need to make a written plan, with specific time lines (that end before the reviewers arrive!), for pulling your files into compliance with the URAC standards. The discipline of going through such an exercise will be necessary, as may be the assistance of temporary help if your staff doesn't have the capacity to handle this task.
4. Look to the future. Once you have your personnel files in order and compliant with the URAC standards, make sure your policies and procedures are written in such a way to keep those files up-to-date. It will do no good to get the files into compliance this year if, for example, you are not doing annual performance reviews for all your employees and getting the results of those reviews into your personnel files.

Well-kept personnel files will help you meet the requirements of a significant number of important Core standards. Getting them into compliance may take some time, so start now.