11-Step Guide to Immaculate Coding Compliance

Shine light on shady claims with these expert tips

The government is growing smarter about targeting areas for investigation - so without a foolproof coding compliance plan, you could be running a high risk of legal trouble. Create connections between the elements of your compliance program with these 11 basic, field-tested strategies.
1. Create specific, written policies and procedures for coding.
Documented guidelines for your facility's coding and compliance policies not only provide a reference for your staff members when they have questions, says Joette Hanna, MPA, RHIA, director of corporate compliance at Baylor Health Care System in Dallas, but also provide evidence of your intentions to report services accurately. Proof that you have concrete requirements for precise, complete, and prompt coding - and that you've informed your employees of the relevant regulations - goes far in the critical eyes of auditors. Make sure you don't write the policies in stone, however, because you will need to update them as regulations change.
2. Connect your compliance program to your billing department.
Compliance can't happen in a vacuum, and without the billing department on your side, you won't accomplish much. Set up a system for these two groups to communicate as much and as often as they like, and your claims can't lose. Some facilities have created specific departments that combine the two aims, Hanna says.
"We've developed a department of billing compliance that's responsible for looking at chargemasters, coding and related issues. If someone identifies a problem or we find something that's getting a lot of denials, they communicate with the proper department and do audits," Hanna says. "We've found it to be very effective."
3. Keep your chargemaster up-to-date.
An accurate, current chargemaster is undoubtedly the most crucial player in the compliance game. You need the people in your health information management and billing departments to verify that the correct codes, charges and edits are entered and to review denials for appeal.
4. Edit claims accurately.
Encourage your coding and billing departments to work together to cover all the inpatient and outpatient claim edits - so you find errors before you drop the bill, Hanna says. While most of these edits will coincide with those of your fiscal intermediary or local medical review policy, you should check coding laws and regulations such as CPT and CMS to ensure you enter the appropriate edits into your chargemaster.
5. Establish a coding compliance work plan.
Once you've got the basics running smoothly - chargemaster, policies, edits - you need to set in motion a specific, goal-oriented work plan in order to verify how well your program works. While you should ultimately tailor your audit target areas to your [...]

- Published on 2003-09-11