“Spring cleaning” is the perfect time to clean up your act at home. Professionally, in an era where healthcare compliance liability lurks around every corner and lax billing practices can cost you thousands, why not make a commitment to review your medical practice policies as the New Year begins?
It all starts with a list, and to help with this, I caught up with Angela Miller, CHC, CMC, president of Dallas-based, Medical Auditing Solutions LLC for some pointers.
“The start of the new year is time for a fresh start – to be proactive and stay in compliance,” Miller says. “Here are a few proactive tips I advise my clients follow, to prevent ‘headaches’ and ‘wallet aches’ later.”
1. A compliance program is required as of March 2013 by any provider including dental that bills Medicare, Medicaid, and/or programs funded by federal or state governments. “Compliance program” in these terms relates to HHS’ Office of the Inspector General’s (OIG) compliance guidance on billing, coding, contracts, and relationships which is now required under the Affordable Care Act. There are approximately 40 policies, that include screening all employees monthly against state and federal exclusion databases.
2. Ensure a healthcare attorney reviews any joint venture, employment work contracts, and possibly leases for potential Stark and Anti-Kickback violations. OIG will be reviewing contractual relationships as part of the compliance work plan.
3. HIPAA is more than the privacy notice provided to patients. All providers – no matter the insurance – must comply with HIPAA and the HITECH Act. The days of using the family member who dabbles in IT/computer work are over, unfortunately. HIPAA and HITECH cover the security of all protected health information (PHI) both paper and electronic, so you must have policies and procedures , a responsible party, and an external IT security audit at least annually.
4. The external audit company should have experience in healthcare or banking because the banks have had these security requirements for years. The penalties are too steep to risk this audit to just any IT company.
5. Now for the fun topic: cash flow management. Providers are concerned with getting business, but rarely inspect billing and collections until it is a crisis.
a. The mail must be opened daily. Medicare has response requirements and if you miss those, you can have your number revoked and might not get it back for two years.
b. Do not have the same person open mail, post cash, and make deposits.
c. Do not hire the cheapest billing person. Check references. Do not hire someone without physician billing experience. Ask them to code scenarios for you or quiz them on their knowledge. Too many medical practices end up in a cash crunch or in trouble because the billing person does not bill correctly. If the person bills incorrectly, because she is told to do so by the provider, take a cautionary note this will eventually come back to haunt the practice.
d. Ensure that your billing person keeps up with the billing rules/changes.
e. Ensure your staff known when it is appropriate to bill “incident-to” the physician and when to bill under the mid-level. This has been a huge audit item for Medicare and commercial plans.
f. Chart documentation will either help you or kill you. It must be legible by three people to be considered valid. The documentation must warrant the billable services submitted. Every office visit is not a level 3-4-5 service. If you have high-risk cases, then use appropriate diagnosis coding to indicate previous or history of miscarriage, abortion, hypertension, etc.
g. Meet at least monthly with your biller or billing/practice management company to review summary reports of revenue, accounts receivable aging by payer, write offs, and denials.
Thanks to Angela for these important tips for a safe and successful 2013.