Medical Coding and Billing Tips | Developing a Compliance Manual

Описание: Medical Coding and Billing Tips -Developing a Compliance Manual
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Q: “Does CCO have any info on developing a compliance manual?”

A: What I did is take information from the manual that I have in my office and my daughter now oversees everything. It really came from the Office of the Inspector General because they have work plans.

But there are seven components that provide a solid basis upon which a physician practice can create a voluntary compliance program:
1) Conducting internal monitoring and auditing,
2) Implementing compliance and practice standards,
3) Designating a compliance officer or contact(s),
4) Conducting appropriate training and education,
5) Responding appropriately to detected offenses and develop corrective action,
6) Develop open lines of communication with employees, and
7) Enforce disciplinary standards through well-publicized guidelines.

Depending on the size of the practice, the physician does not have to implement all seven components of a full scale compliance program. My compliance program is based more as a medical billing service and the OIG has their own plan, but honestly, it’s pretty much all the same. You want to provide a tool to strengthen the efforts of the providers to prevent and reduce improper conduct.

So, we start and we talk about the:
1) Auditing and the Monitoring. You want to choose an individual who will lead and involve other employees in carrying out procedures to ensure standards and procedures are current and complete. You want to focus on high risk areas with the standards and procedures as well as claim submission audits. In other words, you want to make sure that the bills are accurately coded, that the services reflect documentation, services are reasonable and necessary, and ensure that there are no incentives for unnecessary services.

I always divided the roles up. I used to oversee the whole office, but then I would delegate jobs, like, this person is in-charge of the aging and the followup to make sure everything was being done properly. This person would look at how the other billers were posting payments and how the explanation of benefits, remittance advices were coming in, were things getting [written off] when they should have been appealed from the information we get from the physician as well as how the biller would handle anything. If there’s anything at all that is not right, then there should be protocol in place on how to handle it.

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