Update to Arclight Readiness Navigator

{
  "description": "Create a candid internal-only readiness review from de-identified Medicare information, identifying documentation vulnerabilities, template or copy-forward problems, operational causes, corrective actions, and escalation needs. Use when a practice or RCM team wants to learn from an audit without automatically disclosing every weakness in the appeal. Do not use to conceal required facts, alter records, or draft the external response.",
  "included_files": [
    {
      "relative_path": "references/internal-review-protocol.md",
      "size_in_bytes": 4892
    }
  ],
  "name": "record-risk-corrective-action",
  "skill_md_contents": "---\nname: record-risk-corrective-action\ndescription: Create a candid internal-only readiness review from de-identified Medicare information, identifying documentation vulnerabilities, template or copy-forward problems, operational causes, corrective actions, and escalation needs. Use when a practice or RCM team wants to learn from an audit without automatically disclosing every weakness in the appeal. Do not use to conceal required facts, alter records, or draft the external response.\n---\n\n# Record Risk and Corrective Action Review\n\nCreate a separate internal work product. Label it exactly:\n\n> INTERNAL WORKING ANALYSIS — NOT FOR SUBMISSION\n\nThis skill supports truthful quality improvement and response planning. It does not create privilege and must not be described as privileged unless qualified counsel determines that it is.\n\n## Shared operating rules\n\nRead and apply [public-workflow.md](../../references/public-workflow.md) for proportionate answers, de-identified inputs, source verification, and user-requested support. Carry these rules across skill transitions; do not repeat the opening notice.\n\n## Workflow\n\n1. Define the review population: records, claims, dates, sites, templates, staff roles, and decisions actually supplied.\n2. Read [references/internal-review-protocol.md](references/internal-review-protocol.md).\n3. Separate four questions:\n   - What does the contemporaneous record establish?\n   - What is missing, inconsistent, copied forward, or vulnerable?\n   - Is the issue relevant to a stated denial or only to future compliance?\n   - What corrective action is appropriate without changing historical truth?\n4. Classify each finding by severity, recurrence, detectability, and connection to the claims at issue.\n5. Identify the likely operational cause only when evidence supports it. Otherwise label it a hypothesis to investigate.\n6. Design prospective corrective actions with an owner, evidence of completion, validation measure, and due date.\n7. Create an external-treatment field for every finding: `address directly`, `address if needed for truthfulness or a foreseeable issue`, `do not volunteer as unrelated`, or `provider/compliance/counsel decision required`.\n8. Run the overpayment-implications screen for every material finding, including claims outside the audited sample.\n9. Keep the internal review distinct from any external draft. Never copy this table wholesale into a response.\n\n## Required output\n\n### Internal finding register\n\n| Finding | Record support | Claims/issues affected | Severity | Recurrence | Root cause status | External treatment | Owner |\n|---|---|---|---|---|---|---|---|\n\n### Corrective-action plan\n\n| Action | Prospective or retrospective | Owner | Due date | Completion evidence | Validation measure |\n|---|---|---|---|---|---|\n\n### Provider questions\n\nSeparate factual verification from clinical judgment. RCM staff must not answer clinical questions for the treating provider.\n\n### Escalation screen\n\nFlag suspected falsification, materially contradictory testimony, repeated unsupported billing, statistical extrapolation, exclusion or licensure risk, subpoena/CID, or other issues needing counsel or specialist review.\n\n### Overpayment-implications screen\n\nAsk whether a finding suggests that any paid claim, inside or outside the audited population, may lack support or otherwise have been overpaid. If `yes` or `uncertain`:\n\n- do not label it `do not volunteer as unrelated`;\n- preserve the evidence and define the potentially affected claim population;\n- mark `qualified healthcare counsel/compliance decision required`;\n- recommend a prompt, documented, good-faith investigation and quantification under counsel/compliance direction; and\n- state that 42 CFR 401.305 reporting-and-return duties and timelines may apply, without deciding that an overpayment exists or that a refund is automatically due.\n\n### External drafting handoff\n\nProvide only:\n\n- facts safe and necessary to use;\n- disputed issues that must be answered;\n- corrective action that may be accurately stated, if relevant;\n- internal findings that must not be volunteered unless needed for truthfulness or responsiveness; and\n- decisions requiring provider or counsel approval.\n\n## Guardrails\n\n- “Do not volunteer” means omit an unrelated weakness from the response narrative; it never means hide a requested record, a material fact, or a legally required disclosure.\n- Never instruct anyone to delete, overwrite, backdate, or silently revise a medical or billing record.\n- Do not convert a retrospective explanation into contemporaneous documentation. A legitimate amendment, correction, addendum, or delayed entry must preserve the original, be current-dated and attributed, be clearly identified, and contain only facts the author actually knows or recalls. It cannot manufacture a coverage rationale and is not guaranteed to cure missing contemporaneous support.\n- If a template has been corrected, describe the corrective action only if true, supportable, relevant, and approved. Do not imply the corrected template existed during the audited episode.\n- Avoid accusatory labels such as fraud, cloning, or intentional misrepresentation unless established by authoritative findings. Describe the observed record behavior neutrally.\n- Civil investigative demands, subpoenas, fraud or false-claims allegations, exclusion or licensure risk, suspected falsification, and overpayment-reporting decisions require qualified healthcare counsel before a response. Arclight is not a law firm and is not a substitute for counsel.\n- Recommend professional consultation when complexity or risk warrants it. Use the shared support rule for requested contact information; a finding alone does not trigger a publisher referral.\n"
}