O and P Almanac November 2012 : Page 14

n Reimbursement Page By Kathy Dodson, AOPA government affairs department Compliance Program Must-Haves Seven steps to an effective strategy T oday’s crazy environment of uber documentation require-ments means it’s hard enough not to have Medicare question your filed paperwork due to its in-depth documentation demands. So, it’s only natural to be really unhappy if Medicare dings you on the normal, day-to-day documentation it has required all along. A compliance program can make sure that doesn’t happen. Once in place, it will give you and your staff time to concentrate on the documentation that is harder to obtain. A good compliance program consists of seven elements: • developing standards of conduct and written policies/procedures • selecting a compliance officer • implementing effective training and education • establishing open lines of communication • auditing and monitoring your program • enforcing standards • detecting offenses and taking corrective action. Let’s review the importance of each step. Step 1: Develop standards of conduct and written policies/procedures. Standards of conduct are statements about the principles that guide your organization; adherence to them should be considered mandatory for continued employment. For example, your standards might specify that you only bill for services actually rendered, your intent to follow all of the rules and guidelines of federal and state laws as they pertain to health care, and the fact that you will deal with violations appropriately. You need to make sure your statements, which need not be lengthy, adequately convey how you want to run your business. Because these policies are important, each employee should be given a copy to read and asked to sign a statement of receipt. You also should provide annual follow-up training to emphasize the importance of adherence to the policies/standards. Once standards are in place, your next action should be to review and update your policy and procedures manual or create one if none currently exists. That document is extremely critical because it details the day-to-day operations of your company and provides guidance on how to carry out business functions in a correct and efficient manner. New employees, who should be provided a copy and expected to read it, will find the manual especially helpful. In addition, any outside auditors will find that it describes your intent for the company to operate in an appropriate and ethical manner. During your review, remember that the policies are the “position” statements (e.g.,“We will bill insurance companies in a timely manner”), while the procedures are the “how-to” statements (e.g., a list of the steps necessary to bill on a timely basis). While you want to ensure that your policies and procedures are all-inclusive, you should not feel like you will be judged by the thickness of your manual. Just be certain to cover both the development and submission of claims, as well as office administration. 14 O&P ALMANAC NOVEMBER 2012

Reimbursement Page

Kathy Dodson

Compliance Program Must-Haves <br /> <br /> Seven steps to an effective strategy<br /> <br /> Today’s crazy environment of uber documentation requirements means it’s hard enough not to have Medicare question your filed paperwork due to its in-depth documentation demands. So, it’s only natural to be really unhappy if Medicare dings you on the normal, day-to-day documentation it has required all along.<br /> <br /> A compliance program can make sure that doesn’t happen. Once in place, it will give you and your staff time to concentrate on the documentation that is harder to obtain.<br /> <br /> A good compliance program consists of seven elements:<br /> <br /> • developing standards of conduct and written policies/procedures<br /> • selecting a compliance officer<br /> • implementing effective training and education<br /> • establishing open lines of communication<br /> • auditing and monitoring your program<br /> • enforcing standards<br /> • detecting offenses and taking corrective action.<br /> <br /> Let’s review the importance of each step.<br /> <br /> Step 1: Develop standards of conduct and written policies/procedures. Standards of conduct are statements about the principles that guide your organization; adherence to them should be considered mandatory for continued employment. For example, your standards might specify that you only bill for services actually rendered, your intent to follow all of the rules and guidelines of federal and state laws as they pertain to health care, and the fact that you will deal with violations appropriately. You need to make sure your statements, which need not be lengthy, adequately convey how you want to run your business. Because these policies are important, each employee should be given a copy to read and asked to sign a statement of receipt. You also should provide annual follow-up training to emphasize the importance of adherence to the policies/standards.<br /> <br /> Once standards are in place, your next action should be to review and update your policy and procedures manual or create one if none currently exists. That document is extremely critical because it details the day-today operations of your company and provides guidance on how to carry out business functions in a correct and efficient manner. New employees, who should be provided a copy and expected to read it, will find the manual especially helpful. In addition, any outside auditors will find that it describes your intent for the company to operate in an appropriate and ethical manner. During your review, remember that the policies are the “position” statements (e.g.,“We will bill insurance companies in a timely manner”), while the procedures are the “how-to” statements (e.g., a list of the steps necessary to bill on a timely basis).<br /> <br /> While you want to ensure that your policies and procedures are all-inclusive, you should not feel like you will be judged by the thickness of your manual. Just be certain to cover both the development and submission of claims, as well as office administration.<br /> <br /> Step 2: Select a compliance officer. This role can be filled by either an individual or a committee, but the selected entity must be able to devote the time to learn the company’s standards of conduct and policies/procedures. The compliance officer will be responsible for making certain, to the extent feasible, that all employees are following the appropriate procedures and carrying on the business of the company in an acceptable manner. The officer will also be the go-to person for answers to compliance questions and should have direct access to your company’s top management (e.g., president or board of directors.) You also should make clear to the officer that his/her input is wanted and, if the officer has to bring a violation to the attention of management, he/she will not suffer any negative consequences.<br /> <br /> Step 3: Implement effective training and education. Conducting compliance training is as important as creating all the right documents. Having a beautiful compliance manual that just sits on the shelf and is ignored by the staff is worse than not having one at all. Education is the way to prove to the outside world (e.g., auditors) that you know what to do and do your best to educate your staff concerning how the business must operate.<br /> <br /> How you want to provide that training is your decision. You may want to set aside a day once or twice a year for education. Some offices find it easier to do an hour of training once a month during a staff meeting to review several policies in order to cover them all by the end of the year. You also can tailor your education to your audience. For example, if your front office staff contacts insurance companies to determine coverage, you may not need to review that task with practitioners. Just use common sense to decide who must be trained on what, and make sure everyone reads your standards of conduct manual.<br /> <br /> Also, it’s a good idea to log attendance at each training session so no one can come back and say, “You never told me that.” An attendance log also demonstrates to auditors that you are serious about compliance and willing to take the time to keep staff educated.<br /> <br /> Step 4: Establish open lines of communication. Each company will develop this next step—letting your staff know you have an open door policy—in its own unique way. Your employees need to know you welcome their input on how the company is operating—what works, what doesn’t, and how you can improve. They should not fear retaliation if they bring less-than-welcomed news to management. Isn’t it better to find out from an employee that there is a problem than to have it exposed during an audit?<br /> <br /> Establishing open lines of communication doesn’t simply mean ongoing complaint sessions with no attempt to fix the problem. Employees should be encouraged to offer solutions to help ensure there’s a quick remedy. Your staff needs to feel like this is “our” problem, not just “your” problem, and that they are part of the solution.<br /> <br /> Step 5: Audit and monitor your program. Let’s say you implement a whiz-bang program, then just sit back and trust that all is well. Was implementing your program worth the work? Unless you monitor it, you will never know if all that time and investment made sense. So, you also need to set up an auditing program to periodically make sure your policies and procedures are being followed and to learn if anything needs updating, correcting, or deleting. You are free to determine what pace of auditing works best for your company: weekly at staff meetings, a couple of hours once a month, or some other time frame. But certainly, do it more than once a year. If you wait too long between audits, things can get really out of whack and could end up costing you a lot of refunded money.<br /> <br /> Step 6: Enforce standards. What happens if you find problems? That decision rests on whether the issue was caused by a mistake or was deliberate, how long it has been going on, whether there was adequate training on the appropriate procedure, and how much it will potentially cost the company. Your response can range anywhere from simple correction of the problem and reeducation of the staff to termination and perhaps even prosecution, depending on the severity of the issue.<br /> <br /> However you decide to enforce the rules, you must be consistent for all employees. Determine which issues might be the most common and decide ahead of time what disciplinary actions you will take; that will keep you from having an inappropriate response when you are in the midst of a crisis. As part of staff training, make sure everyone is aware that you take compliance seriously and that infractions will be dealt with appropriately and consistently. For emphasis, give them a copy of the enforcement guidelines. Having this message come across as concern for an important issue and not as a threat will be important if you want your staff to be behind you should problems arise down the line.<br /> <br /> Step 7: Detect offenses and take corrective action. After you’ve dealt with the personnel side of the issue in step 6, you have to deal with how to fix the actual problem, often with the insurance company. For example, what steps do you take to make the problem known to the correct authorities, refund any improper payments, fix internal procedures to avoid a repeat of the problem, and set up future audits to make sure the problem doesn’t occur again? If the issue is big enough, the involved insurer may require you to write a plan of action to demonstrate how you will eliminate the problem going forward. Once the issue is solved, be sure to make any necessary corrections to your policies/ procedures.<br /> <br /> The entire process might sound like a lot of work, especially if you are dealing with an intense Medicare audit. But implementing such a program will help eliminate any common errors that can hamper a well-run office and slow down cash flow even more. To help you set up this program, AOPA developed an “AOPA Compliance Program” CD that contains everything you need for implementation, including boilerplate, time-saving policies and procedures you will find helpful. Contact the AOPA Bookstore at 571/431-0865 for more information.<br /> <br /> Kathy Dodson, formerly senior director of government affairs, is a consultant for AOPA. For questions about this column, contact Joe McTernan at jmcternan@AOPAnet.org.

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