Compliance & Reimbursement: Beware When Choosing Consultants: Your Record's on the Line

If you don't know your third-party consultant like the back of your hand, you could find your facility waist-deep in civil (or even criminal) liability faster than you can say "False Claims Act." The consultant isn't the only one who goes down if compliance issues arise during her tenure - so take these precautions to manage your client-consultant relationship with a watchful eye.

Match Experience With the Task at Hand

Find out the whole story behind your prospective consultant's experience in the field, says Gabriel Imperato, JD, attorney at Broad & Cassel in Fort Lauderdale, Fla., and make sure her experience fits the job you need her to do. For instance, if a potential employee has an extensive background with Part A Medicare reimbursement and you need someone to handle primarily Part B tasks, you may want to wait until someone with more Part B experience applies,  Imperato says. Likewise, if your candidate has done work with home health or ambulatory surgical centers - and you need her to streamline your hospital billing - she may not be the best person for the position.

Consider a Group

Your consultant would likely need to supervise less experienced or less knowledgeable staff members, so for starters, she should have the skill set for that task. If you're hiring someone to help revise your chargemaster (CDM), she should have expertise in all the areas relevant to CDM maintenance, such as hospital coding, billing and, ideally, have some clinical background, Imperato says. Because CDM maintenance is - like many other projects for which you'd hire consulting help - a complex task, you may have difficulty locating a single consultant who has experience in all the related fields, so consider contracting with an entire organization for those kinds of jobs.

References Should Be Stainless

Whether your candidate is a single consultant or an organization, check references carefully. You should also review the HHS Office of Inspector General's exclusion list to make sure your potential employee isn't already in trouble, Imperato says. You may even want to ask the consultant or firm for a list of past clients and confirm that they're not on the exclusion list either.

Make Sure You're on the Same Page

Talk about your expectations with your consultant before the project starts so you're sure they're reasonable on both sides and in line with her expertise. This strategy allows you to make changes to the project or your approach before you run into problems, Imperato says. If you discuss the plan beforehand, you're less likely to discover halfway through the job that someone with no Part A skill set is creating a cost report for your Part A claims.

And, keep in mind that financial experts generally aren't also [...]

- Published on 2003-08-13