Audit of Mrs. BLK Hospital — Important Points Requiring Attention
1. Internal Control and Organisational Structure
The auditor should review the organisational chart, delegation of authority, and internal control system prevalent in the hospital. A hospital has several departments (OPD, IPD, Operation Theatre, Pharmacy, Laboratory, Radiology, etc.) and the auditor must understand controls operating in each department.
2. Registration and Licensing
Verify that the hospital holds valid registration under the Clinical Establishments (Registration and Regulation) Act, 2010 (or the applicable State Act), NABH accreditation (if claimed), Bio-Medical Waste Management authorisation, PCPNDT registration, Narcotics and Psychotropic Substances licence, and fire NOC. Non-compliance with statutory requirements is a serious matter.
3. Income Verification
Hospital income arises from multiple streams: OPD consultation fees, IPD charges (room rent, nursing charges, operation charges), laboratory and diagnostic charges, pharmacy sales, ambulance charges, and canteen/cafeteria income. The auditor should:
- Verify that receipts are pre-numbered and all cancelled receipts are on record.
- Cross-check bed-occupancy registers with billing records to detect unrecorded income.
- Verify income from insurance companies and Third Party Administrators (TPAs) with claims settled statements.
- Check that package rates charged to patients are disclosed and revenue is recognised correctly.
4. Expenditure Verification
Key expense heads include medicines and surgical consumables, salaries of doctors, nurses and paramedical staff, housekeeping, laundry, diet/kitchen, repairs and maintenance of medical equipment, and power charges. The auditor should:
- Verify purchase of medicines against GRN, purchase orders, and suppliers' invoices; check for expired stock.
- Ensure narcotics and controlled substances are procured under valid licence and their consumption is reconciled with patient records.
- Examine payroll records — verify qualifications of medical staff claimed as consultants versus employees for TDS compliance under Section 194J and Section 192 of the Income Tax Act, 1961.
5. Stores and Inventory Management
Pharmacy and medical stores represent a high-risk area. The auditor should verify physical stock of medicines, surgical items and consumables, check FIFO/FEFO rotation, identify slow-moving or expired inventory, and examine write-offs approved by competent authority. Bin cards/stock ledgers should be reconciled with accounting records.
6. Fixed Assets and Capital Expenditure
Medical equipment such as MRI, CT scanners, ventilators, and OT equipment are high-value assets. The auditor should verify the asset register, ensure additions are properly capitalised, inspect maintenance contracts (AMC), and check depreciation computation under the applicable method. If the hospital is a company, Schedule II of the Companies Act, 2013 governs useful lives.
7. Insurance and TPA Billing
A significant portion of revenue may come from cashless insurance patients routed through TPAs. The auditor should verify:
- Pre-authorisation letters from TPAs for hospitalisation.
- Final bills submitted vs. amounts settled — examine disallowances and write-offs.
- Sundry debtors ageing for outstanding TPA receivables.
- Any fraudulent claim submissions should be red-flagged.
8. Statutory Compliances
The auditor must check compliance with GST provisions — health care services are generally exempt under Entry 74 of Notification No. 12/2017-Central Tax (Rate) under the CGST Act, 2017, but pharmacy, canteen, and certain diagnostic services may be taxable. TDS deductions, PF/ESI contributions, and Professional Tax must be verified.
9. Government Grants and Subsidies
If the hospital receives government grants (e.g., for COVID-19 care, Ayushman Bharat empanelment, or social welfare schemes), the auditor must verify adherence to grant conditions, utilisation certificates, and whether income has been recognised as per AS 12 — Accounting for Government Grants.
10. Related Party Transactions
If doctors are also promoters or relatives of promoters, professional fees paid to them must be scrutinised for arm's length pricing. Such transactions should be disclosed in accordance with AS 18 — Related Party Disclosures.
11. Bio-Medical Waste and Ethical Compliance
Verify the hospital's compliance with Bio-Medical Waste Management Rules, 2016. The auditor should also check whether the hospital follows MCI/NMC guidelines on ethical practices, particularly regarding referral fees or kickbacks which could indicate misstatement in income or expenses.
12. Fraud Risk Areas
High fraud-risk areas include: billing for services not rendered, ghost patients in IPD registers, inflated consumption of medicines, and manipulation of cash collections at OPD counters. The auditor should apply professional scepticism as required by SA 240 — The Auditor's Responsibilities Relating to Fraud in an Audit of Financial Statements.
Conclusion: The audit of a hospital requires a multidisciplinary approach covering financial, statutory, operational, and ethical aspects. The auditor must obtain a thorough understanding of the hospital's systems, apply analytical procedures to income streams, and focus on high-risk areas such as pharmacy, TPA billing, and cash collections.