HCR 363 Module 7 Audit and Mitigation Plan Example

Course	HCR 363 Risk Management, Auditing and Monitoring for Health Care Compliance
Module	Module 7
Paper type	Audit and mitigation planning paper
Length	About 701 words, 5 pages
Format	APA 7 student paper
School	Arizona State University
Program	BS in Health Care Compliance and Regulations
Updated	October 2026

Free sample paper for HCR 363 Module 7

Audit, Monitor, Mitigate: A Plan for Sonoran Ridge Health's Five Highest Risks

Student Name

BS in Health Care Compliance and Regulations, Arizona State University

HCR 363: Risk Management, Auditing and Monitoring for Health Care Compliance

Instructor Name

Month Day, Year

What this page is doingThe title lists the assignment's three tasks in the order the paper takes them.

Audit, Monitor, Mitigate: A Plan for Sonoran Ridge Health's Five Highest Risks

Auditing and Monitoring

Monitoring and auditing are often named together, but they answer different questions. Monitoring is ongoing review built into operations, usually by the department that owns the process: a coding manager checking a sample of charts each week or a revenue cycle dashboard flagging credit balances as they age. It asks whether controls are working right now. Auditing is a formal, periodic and independent examination, performed by internal audit, compliance or an outside firm, against a defined standard. It asks whether the process, including its monitoring, can be relied on (Office of Inspector General [OIG], 2023).

The two work together. Monitoring results tell the compliance officer where to audit, and audit findings tell managers what to monitor. A program that only audits learns about problems months late; a program that only monitors lets owners grade their own work.

Feature	Monitoring	Auditing
Who	Process owners	Independent reviewers
When	Continuous or frequent	Periodic, planned
Scope	Specific controls and indicators	Defined area against a standard
Output	Dashboards, alerts, quick fixes	Formal report with findings and corrective actions
Purpose	Catch problems early	Confirm reliability and find systemic weakness

The Four Phases of an Audit Plan

Using the surgery center's modifier 59 risk as the example, an audit moves through four phases.

1. Planning. Define the objective (determine whether modifier 59 claims meet Medicare's requirements for distinct procedures), the scope (all ASC claims with modifier 59 from the past 12 months), the standard (the National Correct Coding Initiative policy manual and Medicare guidance; Centers for Medicare & Medicaid Services, 2026), the sample (a statistically valid random sample) and the team, and decide in advance whether counsel should direct the work to preserve privilege if significant problems are likely.

2. Fieldwork. Pull the sample, compare each claim with the operative note and the coding guidance, record findings on a standard worksheet and calculate an error rate. Fieldwork stays factual; auditors note what they find without judging intent.

3. Reporting. Write a report with the objective, method, error rate, examples and root causes, rated by severity, and present it to the compliance committee and ASC leadership. If the audit identifies overpayments, the report triggers the 60-day refund process (42 C.F.R. § 401.305).

4. Follow-up. Confirm that corrective actions were completed and worked, typically by re-auditing a new sample after three to six months.

What this page is doingWalking one real risk through all four phases shows the reader the phases in use rather than as a list of definitions.

Mitigation Strategy for the Top Five Risks

The Five Whys found two shared root causes: processes that cross departments have no owner, and billing policies are reviewed only after a regulator complains. Mitigation begins there, because fixing them reduces four of the five risks.

A policy review calendar, owned by the compliance committee, will put every billing policy on a two-year review cycle. The committee will see progress on all five every quarter, and the board will see it every six months.

Risk	Mitigation	Owner	Monitoring measure	Audit check
Unsupported clinic E/M levels	Assign provider documentation education to compliance; onboarding module and annual refresher; quarterly feedback reports	Compliance officer with medical staff	Percent of sampled visits supported	Annual external E/M audit
ASC unbundling	Add an accuracy measure to coder productivity; require second review of every modifier 59 override	ASC business manager	Modifier 59 rate by coder	Modifier audit described above
Aging credit balances	Update refund authority to add one approver per setting; weekly aging report	Revenue cycle director	Balances over 45 days	Semiannual refund timeliness audit
Expired physician agreements	Shared contract database with automatic alerts to billing and the medical staff office 90 days before expiration	General counsel	Agreements within 90 days of expiry	Annual arrangement audit
Access at role changes	Expand access procedure to transfers; HR notifies IT of every role change	Privacy and security officers	Access reviews completed after transfers	Annual access audit

Conclusion

Monitoring tells managers how their processes are doing day to day, and auditing tells leadership whether those processes can be trusted. A four-phase audit turns a risk into evidence, and a mitigation plan built on root causes turns that evidence into lasting change. For Sonoran Ridge, the most valuable step is the least technical: giving cross-department processes an owner and putting policies on a calendar.

References

Centers for Medicare & Medicaid Services. (2026). National Correct Coding Initiative policy manual for Medicare services. https://www.cms.gov/medicare/coding-billing/national-correct-coding-initiative-ncci-edits/medicare-ncci-policy-manual

Office of Inspector General. (2023). General compliance program guidance. U.S. Department of Health and Human Services. https://oig.hhs.gov/documents/compliance-guidance/1135/HHS-OIG-GCPG-2023.pdf

Reporting and returning of overpayments, 42 C.F.R. § 401.305 (2024).

Reading the HCR 363 Module 7 assignment instructions

Assignment 7 shares Week 5 of HCR 363 with the Five Whys and asks for three things in one paper: a comparison of auditing and monitoring, a description of the four phases of an audit plan and a mitigation strategy for your top five risks. The first two are conceptual and come from the week's reading on identifying risks, tools and coverage and the elements of a monitoring plan; the third is applied and should build directly on the root causes you found in Assignment 6. Treat the three parts as connected. The comparison explains why a program needs both kinds of review, the audit phases show how a risk becomes evidence and the mitigation strategy shows what happens next. It is worth 65 points, and the Week 6 work on the OIG Work Plan and the final board presentation draw on it.

Inside the HCR 363 Module 7 example

The sample opens by separating monitoring from auditing in plain terms, cites OIG's compliance guidance and lays the differences out in a five-row table before explaining how the two feed each other. The audit phases are described through one real risk, the surgery center's modifier use, so each phase shows its decisions: objective, scope, standard, sample, privilege, fieldwork worksheets, a report that can trigger refunds and a re-audit. The mitigation section starts from the two shared root causes found in the Five Whys, then gives a table with one row per risk: the mitigation, its owner, a monitoring measure and an audit check. A closing paragraph names the governance that keeps the plan moving.

Reading the HCR 363 Module 7 grading rubric

Assignment 7 earns up to 65 points on its Canvas rubric. A strong paper distinguishes auditing from monitoring accurately, by who performs them, how often and why, explains how they work together, describes all four audit phases with the decisions each requires and develops a mitigation strategy for each of the top five risks that follows from their root causes, with owners and ways to measure progress. Points are lost when auditing and monitoring are treated as synonyms, when the audit phases are listed without explanation, when mitigation is generic, such as "provide training" for every risk, and when the strategy ignores the root cause analysis from Assignment 6. Readers also notice whether the plan has an owner for each action, since unowned actions are the most common reason mitigation fails in practice.

HCR 363 Module 7 help: mistakes that cost marks

Define monitoring and auditing by who does them before anything else; the rest of the comparison follows. Use one of your own risks to walk through the audit phases, since an example shows you understand the decisions involved. Start mitigation from your root causes, not your risk names. Give each action an owner, a measure and an audit check. Include at least one change to an incentive or a policy, not only training. Keep the table readable. If your root causes overlap, say so and fix them once. The desk can check whether each mitigation actually reaches its root cause.

Write yours, or have the desk draft it

This paper is an original model document written by our desk, not a submitted student paper and not an official Arizona State University document. Read it for the moves, then write your own to the instructions in your classroom. If you want one built to your exact prompt and rubric, the first custom sample is free and arrives in 24 to 48 hours.

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HCR 363 Module 7 questions, answered

Where can I find a free HCR 363 Module 7 sample paper?

The page above carries a complete Assignment 7: auditing versus monitoring, the four audit phases and a five-risk mitigation plan.

What is the difference between auditing and monitoring in compliance?

Monitoring is ongoing review by process owners; auditing is a periodic, independent examination against a standard.

What are the four phases of an audit plan?

Planning, fieldwork, reporting and follow-up.

How should a mitigation strategy be built?

From the root causes of each risk, with an owner, a monitoring measure and an audit check for every action.

When should counsel direct a compliance audit?

When significant problems are likely, so that privilege may protect the work while the organization decides how to respond.

HCR 363 Module 7 Assignment 7: Auditing, Monitoring and Mitigation Planning Example