Practice Management Alert

Hint: You cannot overcommunicate when it comes to expectations concerning compliance.

Interpersonal relationships, especially in business settings, thrive when everyone communicates fully about expectations. If your practice is concerned about thorny issues like compliance — and it should be, because the stakes are high — then you should invest the time and energy into crafting policies and procedures, and checking in on whether your practice is meeting its marks.

Establishing an internal auditing program is one way of catching potentially huge errors before they get out of hand.

“A compliance program is really intended to develop and implement internal controls and procedures that promote adherence to statues and regulations for federal health care programs, private insurance program requirements, but also the program will strengthen efforts to prevent and reduce improper conduct and improve quality care to patients,” says Terry  Fletcher,  BS,  CPC,  CCC,  CEMC,  CCS,  CCS-P,  CMC,  CMCSC,  CMCS,  ACS-CA,  SCP-CA,  owner of Terry Fletcher Consulting Inc. and consultant, auditor, educator, author, and podcaster at Code Cast, in Laguna Niguel, California.

Use these expert suggestions from Fletcher to start a written compliance manual; build an entire compliance program — complete with auditing check-ins — out of that.

Formulate a Compliance Program, Manual

A compliance manual is the biggest thing you should start with — like a recipe, it gives you the guidance (and documentation thereof) you need to follow to ensure consistency and accuracy.

First thing’s first: Make a list of what you want to implement in your program and how you want to address it, Fletcher says.

This can include the development of a code of conduct, as well as putting policies and procedures in writing.

Next, appoint a staff member as a compliance officer to monitor your practice’s efforts. Depending on the size of your practice, the compliance effort should really be monitored by a team, so various employee roles and perspective are represented.

“In a medical practice, it has to consist of a medical provider. So, a physician has to be part of it. It would be helpful if you could bring in a midlevel provider, if you have one, and also a coder and a biller. An administrator also needs to always be a part of that conversation,” Fletcher says.

When selecting a physician, you need to choose someone who has recently passed an audit and is pretty compliant in their documentation efforts, Fletcher says. Otherwise, behaviors that you’d like to see change may be upheld.

Education is Crucial

The significance of communication really comes into play when making sure everyone is on the same page. While you or your new compliance officer or team may get frustrated or exasperated with employees who aren’t meeting your expectations, it’s unfair to do so unless they fully understand your expectations. Focus on ethics in order to ground employee understanding in why you’re making changes, as well as detailing practice policies and procedures.

“Develop accessible lines of communication such as staff meetings regarding fraudulent or erroneous conduct issues, a community bulletin board to help keep practice employees updated regarding compliance activities, and that really needs to be refreshed,” Fletcher says.

Prioritize the “enforcement of disciplinary standards, to ensure employees, including physicians who are employed, are aware that compliance is treated seriously in your practice and violations will be dealt with consistently and uniformly,” she adds.

Make sure this is part of your compliance manual, too.

In a lot of practices Fletcher works with, a little bit of training would have gone a long way to avoid certain circumstances that could expose a practice to not just an audit but a noncompliance sort-of meltdown for reimbursement, she says.

Be Consistent

Formulate appropriate responses to detected violations by investigating allegations and having a plan to disclose incidents to the appropriate government entity.

“If you find blatant over coding in procedures or E/M [evaluation and management] service visit codes and there are some issues there or you found something that was not good, there’s a provision within the Medicare bylaws that says that you have to self-report. I’ve dealt with a lot of different practices that have dealt with that and it does get a little bit ugly, so you want to make sure you’ve got procedures and policies in place to deal with that,” Fletcher says.

Internal or External are Both OK Choices

When it comes to checking in on your progress, the who matters a lot less than the how or when.

“When you talk about audits, not only can you do them internally, as long as you’ve got the staff who understands what audits should look like and how to perform them, but also you can hire somebody externally. Use somebody who is versed in your specialty; do not hire somebody who just says, ‘By the way, I audit.’ Make sure you get references, information on them, and find out how successful they’ve been in their auditing processes,” Fletcher says.

If you or an external auditor do find something amiss, make sure you have processes in place to evaluate your claims submissions and what’s appealed, as well as a plan to deal with any physicians who are noncompliant with their documentation, she says.

Your basic recipe for a response? “Identify, reprimand, education, follow up, reprimand again, continue education,” Fletcher says.