Urology Coding Alert

Don’t forget: Strive to build a positive culture of compliance.

Recently, at the 2021 HEALTHCON session “Effective Compliance Policies,” instructor Rhonda Buckholtz, CPC, CDEO, CPMA, CRC, CMPE, CHC, COPC, shared some helpful tips you can follow to implement effective compliance policies in your practice.

Read on to learn more.

Tip 1: Clarity and Accessibility Key for Compliance

Your compliance policies need to be developed for your organization’s specific needs, Buckholtz said. You should also develop them in a language everyone can understand.

“Our role [in compliance] is to explain the rules in a way someone can understand,” according to Buckholtz. “That’s what we are doing with our compliance policies.”

Additionally, you must check the accessibility of your compliance policies. Make sure everyone knows where the policies are located for reference.

“Access can be a barrier because if you keep the policies on paper, you’re tied to wherever that binder may be located,” Buckholtz said. “You have to make sure they are easily accessible to everyone.”

If you have multiple locations, you need to have multiple binders. Then, you need to look at tracking because when you have multiple binders, you could have a situation where people might be tweaking the policies and moving them around, according to Buckholtz.

Tip 2: Review Compliance Policies Annually

You should review your completed compliance policies at least on an annual basis, according to Buckholtz. You can split the policies up depending on how many you have, what your goals are, and how many people are on your team.

Also, Buckholtz said she visits her locations on site and takes a checklist of everything she wants to review. The checklist varies depending upon the location; for example, whether it’s an ambulatory surgical center (ASC) or a clinic.

This formal walkthrough helps her determine what changes need to be made, Buckholtz said. Once she has performed the review onsite, she can see which policy isn’t working or isn’t as effective as she thinks it should be. Then she can tweak that policy as needed.

Pro tip: You should always keep your old policy whenever you make revisions, Buckholtz said. Never throw the old policy away. Your policies will evolve, and you want to show that evolution. You should also inform everyone on your team when you make a new policy and make sure they have a good understanding of the change.

Tip 3: Log Changes and Date Revisions

You should always keep a log and track any changes you make to your compliance plan, Buckholtz said. You always want to know what revisions were made.

Pro tip: Version control is a method you can use to show these improvements, according to Buckholtz. A numerical tracking system is a helpful way to track the different versions of your compliance plan.

You should always date any new revisions you make, Buckholtz said. Also, make sure if you revise something out of your normal schedule, you note why you made the change. You will want to include what rule changed and what prompted the change.

You can use software to track your policies or you can use an Excel worksheet. You don’t have to use a fancy system, but you do want to keep a log of exactly why you have changed your policies, Buckholtz added.

Tip 4: Keep Track of Often-Used Codes

You should also have good policies and procedures for the coding and billing your practice does, Buckholtz said. This doesn’t mean you need a policy for every code your physicians use, but you should identify your high-risk areas.

For example, what areas do your physicians struggle with providing complete documentation? Do you see issues with a particular modifier? Or do you see issues with multiple procedures performed on the same day?

Tip 5: Create Positive Culture of Compliance

As you create your compliance program, make sure you mingle with your team, are visible, and build collaboration, Buckholtz said. A positive culture of compliance is so important.

“When people understand why we are doing things or what the need is, they become much more engaged and likely to comply,” Buckholtz added. “Do walkthroughs. Review patient complaint logs. Conduct employee interviews and ask them what their biggest frustrations are and what’s really happening in their world.”

Also, you should never become territorial with your compliance policies. Remember, you want all of your policies to be effective. It might be a good policy, but it just might not work for your organization. However, this doesn’t reflect negatively on you, Buckholtz said. Just tweak the policy so it is effective for your organization.

Editor’s note: Want more great info like this? You can now register for the upcoming 2021 HCON regional conferences: https://www.aapc.com/medical-coding-education/conferences/. Visit www.aapc.com for more info.