Practice Management Alert

Ramp Up Revenue in 2005 With an Annual Compliance Plan Review

Start the New Year with 7 steps to make billing compliance a breeze

There's no better job security for a billing staff than being able to prove you're current in billing and coding guidelines - and that you're making more money because of it. Keeping up with your compliance plan is where it all begins.
 
Once a year, if not more often, you should review your compliance plan to "make sure everything is still up-to-date and current," says Catherine Brink, CMM, CPC, president of HealthCare Resource Management Inc. in Spring Lake, N.J. Maintaining your compliance plan allows you to ensure your billing procedures are compliant and efficient for maximum reimbursement. And continual enforcement shows your practice's active commitment to compliance in the event of an audit or other external investigation.
 
Consider these seven expert steps to keep your compliance plan up to speed:
 
1. Create a compliance calendar. You should define and prioritize activities that are date-specific relative to your compliance plan, says Curtis J. Udell, CPAR, CPC, CMPA, senior advisor with Health Care Advisors Inc. in Annandale, Va. Assign activities such as chart reviews, code updates and fee updates to the appropriate months and keep this calendar with your compliance plan so you can refer to it throughout the year.
 
2. Keep a compliance checklist in the front of your compliance manual. Once you have your timeline defined, the next step is documenting your activities. Have a spreadsheet or checklist where you can record dates and compliance activities as they occur, Brink says. If your office is subject to an outside investigation, documentation that you maintain your compliance plan could be your saving grace.
 
Sample record:  

  • 10/26/04 - Updated ICD-9 codes
  • 12/28/04 - Updated CPT codes and Medicare fees
  • 1/5/05 - Annual review and revision of compliance plan
  • 2/10/05 - Biller/coder education session conducted

    3. File all important documentation in the relevant sections of your compliance plan, Brink says. For example, file the appropriate documents under the "Education and Training" section anytime you complete an in-house training or education session, or anytime an employee attends an off-site education function. Recording what you did in the front of your manual is great - having evidence to back it up is a must.
     
    4. Assess your plan's effectiveness annually. Most compliance plans state that you need to measure the benefits of the plan every year. "That's where most compliance plans and the people who are responsible for them fall short," Udell says. Never assume your compliance plan is working to cut down on billing errors just because you have it all on paper, he says. You need to challenge your compliance plan and test your policies and procedures, he says.
     
    Hint: "Try to measure where you were last year compared to where you are this year for revenue" and physician-billing compliance, Udell says. This is the most direct indicator of whether your compliance plan is working.
     
    Best practice: Make changes and updates to your compliance plan as they happen during the year. Reserve your annual review as an opportunity for reflection on accomplishments and what areas need improvement.
     
    5. Prove your worth to physicians with data that show your compliance plan works. If you've implemented and followed through on the policies set out in your plan, chances are you'll have the numbers to prove it. And there's no better job security than showing how you've helped your practice make more money, Udell says.
     
    6. Arrange internal audits by an outside consultant. If you don't have the means to invest in a routine professional auditor, your bottom line can also benefit from a professional yearly audit. While conducting internal audits with in-house staff is also a good idea, an objective third party will often uncover problems you overlooked due to familiarity with your office's workings. Consultants also have the tools to process your large data sets quickly and identify all the little errors, Udell say.
     
    7. Consider outsourcing your compliance officer. One of the mainstays of every compliance plan is assigning a compliance officer to oversee the implementation of your plan's policies. Small practices may find it easier and more affordable to have the billing manager act as compliance officer, but larger practices (think five-physician practice or greater) will probably benefit from the services and objective perspective of a professional compliance officer, Udell says.
     
    Udell's company can create a compliance plan and manage the plan within a practice. "We set it up so I serve as the chief compliance officer," and then an on-site billing employee serves as the compliance coordinator who runs quarterly reports and helps coordinate activities, he says.
     
    Stay tuned: Do you still need a compliance plan? Next month we'll tell you how to get started and build a plan that fits your practice.

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