Outsourcing your billing to a third party will not alleviate your compliance duties or reduce your risk of a government investigation. Conversely, a relationship with a third-party biller can increase your compliance obligations and raise audit risks.
The Office of Inspector General (OIG) is scrutinizing the relationships between billing companies and the providers that contract with them to determine “the impact of these arrangements on physicians’ billing,” according to the agency’s Work Plan (available at www.oig.hhs.gov).
The OIG wants to ensure that third-party billers are not driving up physician billing to increase the perceived value of their contract and what physicians will pay them. One of the biggest areas that the OIG will review is the arrangements where providers pay billing agencies a percentage of the reimbursement they collect—particularly if the billing agencies try to influence what codes the physician bills.
Reduce your compliance risks by ensuring that your contract:
- Includes a mutual indemnification clause;
- Guarantees that the billing company and its employees can legally bill Medicare;
- Assures that the billing company’s employees are familiar with all payer rules;
- Details the claims development and submission process;
- Requires the billing company to retain records and documentation related to your claims;
- Allows you to access and audit your claims data;
- Requires the billing company to notify you as soon as it detects aberrant billing patterns or questionable claims; and
- Includes a right to terminate the contract immediately if you have substantial compliance concerns that the billing company cannot address.
If you have additional questions about compliance issues, contact Antanya Chung, CPC, CCP, at (404) 633-3777, ext. 818 or [email protected].
