The key is nothing more than objectivity and impartiality of the process which boils down to the integrity and veracity of the person doing the audit.
Well said Randy, and this is our contention to his argument. Granted, 'letter of the clause' he has some ground to stand on... but an NC?? Looking at the '
intention of the clause' he has almost none, especially since he cannot show the lack of impartiality.
When he wrote this NC he included it with another "concern" of our IA process: not referencing what format of the audit report to use
. I never told my internal auditors, "use this audit form" and made it an ISO document; just 'this is the information I want and here is a possible format'. Some chose to use Word to write their report, others Excel. My closure of this NC was solely to create a "reference" document for auditors and provide samples of both versions of the IA report form... never addressed the EMR auditing concept... and he accepted it to close the NC.
We will also add a statement that the EMR has been chosen partially based on their ability to be impartial when auditing. We'll see what transpires at their post review and next year when they audit for renewal.
Thanks everyone for your input, it was helpful.
