The review is coming. The only question is who reads it first.
External QA is independent oversight of your documentation, the whole organization, every month. Recent CMS changes made document review, not the survey, the regulatory event agencies face most often. We read the records you bill the way a contractor will, while there is still time to fix what they would find.
condition-level deficiencies across External QA clients in their last full survey cycle.
oversight cycles a year. A rhythm your team plans around instead of a scramble it survives.
to reply on a document request for records we already cover. A phone call, not a ticket.
What happens every month, every quarter, every cycle.
Oversight only works if it is predictable. Your team knows what is coming, and compliance stops being a project that ends.
Async office hours
A running channel with your reviewer. Quick questions, documentation gut-checks, reviewer-pattern clarifications. Answered same or next business day, by the person who reads your records.
Independent documentation review
A rolling review of the records you bill, worked through the D.O.C.U.M.E.N.T framework and scored against the standard a reviewer applies. Written findings the same month, with a review call.
Re-certification and PIP cycle
Deep review of the framework in practice plus a facilitated performance improvement cycle covering indicators, root cause, and the documented loop your QAPI program is supposed to close.
Document requests & post-survey
ADR, TPE and SMRC replies, condition-level deficiency responses, corrective action plans. On records already under coverage this is included; a large retrospective pull is quoted per claim.
Everything, org-wide, on one monthly fee.
Documentation oversight and your QAPI program are the same job. One produces the evidence the other is supposed to act on. Running them apart is why both underperform. One fee. No hourly billing, no out-of-scope letters.
Monthly documentation review + findings
A rolling sample matched to your diagnosis mix, reviewed against the criteria that decide payment. Written findings with severity, the recommended fix, and the exposure each gap represents.
Quarterly D.O.C.U.M.E.N.T re-certification
Full framework review: program health, IDT cadence, and the narrative patterns that carry eligibility. A written re-certification signed by your reviewer.
Quarterly PIP cycle facilitation
A real performance improvement cycle, facilitated end to end (plan, do, study, act) with your team in the room. The loop gets closed and the closing gets documented.
Indicator selection & data plan
The measures your program actually runs on, chosen because they predict exposure rather than because they are easy to collect. With the data plan that keeps them honest.
Root-cause analysis with your team
Findings traced to the habit that produced them. Fixing a chart fixes one claim; fixing the cause fixes the next hundred.
Board-ready QAPI documentation
The written record your governing body is required to see and a surveyor is entitled to request, produced as a by-product of the work, not reconstructed the week before a meeting.
Async office hours
A running channel for documentation gut-checks, reviewer-pattern questions, and the “should we worry about this?” moments. Same or next business day.
Document request & post-survey response
Requests on records already under External QA coverage are answered within 24 hours and included in the retainer, because we reviewed those notes before they were billed. Large retrospective pulls are quoted per claim.
Quarterly leadership review
Ninety minutes with your DON, administrator and QAPI lead. Trends across the quarter, emerging reviewer patterns, and where the money is leaking.
Annual pre-survey mock
A full mock survey once a year, scheduled before your next anticipated window. Same rigor as the Readiness Program mock, included rather than billed.
The PDSA cycle, run quarterly, every quarter.
Plan, Do, Study, Act is what CMS expects a QAPI program to actually be doing. This is how each rotation runs, with what we own and what your team owns called out at every stage.
Plan
Define the indicator, the patient population, the measurement plan, and the target. This is where most internal QAPI fails: vague indicators or unmeasurable targets.
ILS CARE owns: Indicator selection, baseline measurement, target-setting, and the data collection plan that survives audit.
Do
Implement the change at the bedside, in the chart, in the workflow. Small-scale at first, then scaled. Documented as it happens, not after.
Your team owns: Frontline execution. We provide the protocol, the monitoring tool, and the training. Your clinicians do the work.
Study
Compare the result against the target. Run root-cause analysis on what fell short. Identify which interventions actually moved the indicator and which did not.
ILS CARE owns: RCA facilitation, data analysis, and the written findings memo for the QAPI committee and board.
Act
Adopt what worked. Adapt what almost worked. Abandon what did not. Scale the change permanently into policy, training, and the chart. Then start the next cycle.
ILS CARE owns: Policy update drafting, training rollout plan, and the next-quarter PIP charter for the QAPI committee.
The Leadership Report.
Every cycle produces one document, built the same way each time so you can read it in five minutes and compare it to last month. It is written to be handed to a board, not decoded by one.
Executive risk summary
One page. Where you stand this cycle, what changed since last, and what it is worth in exposure. Written for the person who signs the check and has ninety seconds.
Highest-risk findings
Ranked by what they cost you, not listed by where we found them. The three things worth your attention this month sit at the top, and everything else waits.
Documentation themes
The pattern underneath the findings. One weak narrative is an incident; the same weak narrative in nine charts is a habit, and habits are what contractors sample for.
QAPI linkage
Every theme mapped to the performance improvement cycle that addresses it, so your QAPI program is driven by evidence you can point at, and the linkage is already documented.
Recommended next actions
Who does what, by when. Named owners and dates, so the report ends in a decision instead of a discussion.
Placeholder, client quote pending.
Why internal programs fail their own audit.
Not because the people are weak. Because you cannot mark your own homework, and the person who wrote the note is the last one who can see what is missing from it.
| Dimension | Internal QAPI or hourly retainer | ILS CARE External QA |
|---|---|---|
| Independence | The team reviews its own documentation and finds what it already believes is there. | An outside reader with no stake in the answer, applying the standard a contractor applies. |
| Billing | Hourly. A surprise on every invoice. | From $3,500/month, banded by census. Zero hourly billing, ever. |
| Document requests | A billable add-on, often ruled out of scope. | Included within 24 hours on records we already cover. |
| QAPI | A separate binder, updated before the board meeting. | Driven by the findings, closed quarterly, documented as it happens. |
| Who does the work | A rotating junior associate. | A senior clinician, every cycle, every review. |
| Exit | Auto-renewing, with notice periods. | Six-month minimum, then month to month. Leave when your team is ready. |
What teams ask before committing.
How is the monthly fee set?
By your average daily census. The $3,500 monthly minimum covers agencies up to roughly 15 ADC; larger agencies move up a census band, and we size it with you on the call. Each band includes a set volume of notes reviewed, so the number you budget is the number you pay. The first month is payable at signing and monthly in advance after that. Six-month minimum.
Does this replace our internal QAPI program?
It runs it. External QA absorbed what used to be sold as a separate QAPI engagement, because splitting them was the problem: the documentation review produces the evidence, and the QAPI cycle is what acts on it. You keep your committee and your governing body; we bring the independence, the cadence, and the written record.
Do we need the Readiness Program first?
Not any more. External QA is the front door now, most agencies are facing document review long before they are facing a survey. If a survey is your live problem, the Survey Readiness Program is the better first move.
We just got an ADR. Is this the right service?
It depends which records they pulled. If the request covers notes we were already auditing, answering it is included here. If the letter landed before we were engaged, or reaches back across claims we have never seen, that is Documentation Defensibility: priced per claim, returned in seven days. Either way, External QA is what keeps the next letter from mattering.
What if we need more in a given month?
Document request and post-survey work on records already under coverage is included and never hourly. Larger one-off needs, training waves, new-site onboarding, diligence, are scoped separately so your monthly fee stays a number you can plan on.
What happens if our reviewer is unavailable?
Your engagement is staffed by a named senior clinician, not a rotating queue. If they are booked during your review window, that cycle moves within the same week rather than dropping to a junior associate. Response-time commitments on document requests stay in force.
Does this work for multi-site groups?
Yes, priced per site with central governance scoped to the group. Three sites is where the maths turns: that is the point at which no single person can still see across all of them. See Enterprise for the multi-site model.
The rest of the ladder.
External QA is the ongoing, org-wide door. If something more specific is in front of you, start there.
Documentation Defensibility
A contractor pulled specific records and the clock is running. Bounded to the claims in the letter, flat $750 per claim, returned within seven days.
From $750 per claim →ProgramSurvey Readiness Program
The full build when the survey is the event you are preparing for. Eight weeks, installed in your EHR rather than rented from us.
From $20,000 →Book a Strategy Call. See if the rhythm fits.
Fifteen minutes. We confirm you are at the right place on the ladder and either bring you on or point you honestly at the step that serves you better right now.