The practice compliance and standards should be part of an employee’s training and orientation. They should be educated on the policies and procedures and have a signed sheet in their employee file, stating they understand the practice policies and commit to following the rules.
Designate a Compliance Officer or Contact Person
Prior to completing any audits or identifying risk areas, physician practices will need to assign a staff member as the compliance contact person or hire a compliance officer. The compliance officer or contact person is responsible for all compliance-related activities, including developing a compliance program/plan, creating a corrective action plan and enforcing adherence if needed. In medium to large practices or organizations, there is a full-time compliance officer who is responsible for overseeing the implementation, establishment and enforcement of the compliance program/plan. However, in smaller practices due to limited resources, the contact person designated to oversee the compliance plan can be the office manager or a certified coder or biller.
Conduct Appropriate Training & Education
Education and training are essential parts of a practice’s compliance program and should be tailored to the size and need of your practices. Employees are required to understand how and why it is important they comply with guidelines of the practice’s compliance plan. Training can be done through various methods, such as in-office training, compliance meetings and other training seminars.
In-office training, which should include such topics as fraud, abuse, coding and documentation, can be the most inexpensive and valuable training. The training should involve providers, nurses, medical assistants, coders, billers and front office staff. Some insurance companies have been known to ask if providers and their staff attended compliance training, so each staff member should have a record of any type of compliance training in their employee file.
Respond Appropriately to Detected Offenses & Developing Corrected Action
Violations of federal and state regulations for coding and billing can place a practice in jeopardy. Every practice should establish a policy and procedure on how to respond when a coding or billing error is detected. Your compliance plan must include clear steps on how it will work to resolve any violations that occur and take action as necessary. The compliance plan should have individual steps to address the scenarios of overcoding, undercoding, coding for services not rendered, returning overpayments, and fraud and abuse.
Develop Open Lines of Communication
Of all the components, communication is the most vital. Providers will need to have an open line of communication for all employees. Because everyone in the office plays a role in the ongoing achievement of the office compliance plan, regular meetings should be held, and goals, requirements and expectations of the office compliance program/plan should be communicated. Communication routes include e-mail messages, bulletin board postings, daily or weekly staff meetings and educational sessions.
