Podiatry Coding & Billing Alert

Hint: Always record compliance updates, including different versions.

If you are not sure how to build an effective compliance program, you can start with annually reviewing your compliance policies and tracking the most used codes in your practice. In the 2021 HEALTHCON session “Effective Compliance Policies,” instructor Rhonda Buckholtz, CPC, CDEO, CPMA, CRC, CMPE, CHC, COPC, discussed different steps you can take to create successful compliance policies.

Read on to learn more.

Step 1: Conduct Annual Review of Your Compliance Policies

You should review your completed compliance policies on at least an annual basis.

You can split the policies up depending on how many you have, what your goals are, and how many people are on your team, Buckholtz said. She sets her goals quarterly.

Also, according to Buckholtz, she visits her locations onsite and takes a checklist of everything 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.

Tip: You should always keep an 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.

Step 2: Track Codes Your Practice Uses Frequently

Make sure you have compliances and procedures for the coding and billing your practice performs most often.

This doesn’t mean you need a policy for every code your physicians use, but you should identify your high-risk areas, Buckholtz said.

You can ask questions such as the following to figure out which areas to cover:

• What areas do your physicians struggle with providing complete documentation?
• Do you see issues with a particular modifier?
• Do you see issues with multiple procedures performed on the same day?

Step 3: Record Compliance Updates

Another step you can take to building an effective compliance plan is to always record and track any changes you make.

Tip: Version control is a productive 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.

Always date any new revisions you make, Buckholtz added. 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, Buckholtz said. 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.

Step 4: Make Policies Accessible Everyone

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.”

Step 5: Develop Positive Culture of Compliance

As you create your compliance program, make sure you mingle with your team, be 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.