It is foolish to think that HIPAA is all there is to Compliance!
If an Inspector from the Office of Inspector General (OIG) visited your practice today, would they see some tell-tale signs of non-compliance?
- Computer screens and patient records in plain sight. This is a big red flag! It could mean your office is lacking in confidentiality and security policies.
- Coding books are outdated. Coders not using current books or software are a compliance risk to your practice. Using outdated codes will cause unnecessary denials and appeals.
- Memos or cheat sheets posted for coders. Its acceptable to use a cheat sheet if you are a specialty and want to keep the most frequently utilized category at your fingertips. An Investigator might see this as a problem if cheat sheets only list the higher paying Evaluation & Management or procedure codes. Lists should include all codes, not just the highest reimbursement. Remember, it is not appropriate for the coder to change a diagnosis code just because it is the only one that will get paid for certain procedures. The medical policies (LMRPs) are reference tools only.
- Compliance Contact not posted. Designate someone or a committee to address compliance problems within the practice. Confidential employee and/or patient complaints with follow-up and resolution will prevent legal problems.
- A Compliance Manual sitting on a shelf collecting dust. This manual should be a reference tool and updated regularly as policies and procedures change.
Medical practices can avoid significant civil and criminal monetary penalties by utilizing a Consultant to review and establish compliance policies and procedures.
- Our Specialist will develop and write internal medical practice Compliance Plan
- Implementation of Plan with Management, Staff, and Physicians
- Ongoing regularly scheduled meetings with Management and Staff for internal auditing and monitoring processes