Wiki New Compliance Plan for New Mental Health Office

[dogwhisperer36]

Hello,

I am the manager of a small mental/behavioral health office. They are just starting out and need a compliance plan. I have looked through the OIG's guide and am overwhelmed. Is there anyone willing to share an outline of their compliance plan for their office? I really just need to know where to start.

I have worked for 15+ years as a biller/coder for a large company and the compliance training was always provided for us by their legal/compliance team, so I never had to even think about it.

Thank you,

Tara

 

[TThivierge]

Hello,

I am the manager of a small mental/behavioral health office. They are just starting out and need a compliance plan. I have looked through the OIG's guide and am overwhelmed. Is there anyone willing to share an outline of their compliance plan for their office? I really just need to know where to start.

I have worked for 15+ years as a biller/coder for a large company and the compliance training was always provided for us by their legal/compliance team, so I never had to even think about it.

Thank you,

Tara

Hi Tara
Goggle the concept compliance plan of beh health..sure lots of formats to manipulate to your practice. I can tell you some things I notice which should be included in beh health documentation& monitored. Ensure use template format listing in record if face to face or telehealth, phone, minutes on record and ensure GIVE a DIAGNOSIS even if assessment! Ensure the clinician professional title is listed in record & name prove documentation (attestation)too. This applies to docs, providers PA or NP, therapists and peer review or nurses..that data helps the med coder. Ensure the provider describe pt problem and select the stage pt. is in see dx blocks of F32, F01-F02, F10,F41 and if pt has past history use proper Z dx codes(last on claim) or list chronic conditions if applicable. If pt deals with chronic pain G89..please list WHY or REASON is it due to G47.33 or M54.50 ,C61, B20, or F32 or G82 as examples. If pt homeless use more than just Z dx code...list reason cause ill or depressed or Etc. Ensure define words vs history of vs remission on record so coder understands. Also certain staff can be linked to certain CPT codes or job duties. Group therapy cannot be more than 10 patients at a time. Add credentialing data completed per payer for each provider, treatment plan approved by some payers and documentation due in timely manner
Well I hope this data helped you .
Lady T

 

[amyjph]

The practice attorney/a healthcare compliance legal group may be the best resource to ask for guidance if it's brand new.
If you are doing it manually go by the OIG Individual and Small Group one. https://oig.hhs.gov/documents/compliance-guidance/801/physician.pdf
There is a lot to this, I am not sure I would attempt to do it all manually for a brand new practice. It's not just the coding and billing aspect, there is so much more to it when we say compliance. Especially if Medicaid or Medicare are involved and being mental health.
You could also consider a consultant or something like HCPro just to get it started. https://hcpro.com/
Below is an example of help within the APA website. If the provider belongs to any specialty society like this, then can look there for help too.

https://www.psychiatry.org/File%20Library/Psychiatrists/Practice/Practice-Management/Starting-a-Practice/Online-Practice-Handbook/40-compliance-programs.pdf

 

[jkyles]

I would just add that a written compliance plan should be based on what the individual practice knows it can accomplish, not what it thinks looks good or what another practice is doing. You often hear "If it isn't documented, it wasn't done." But for compliance plans it is "If you can't do it, don't document it."

If a practice goes through the trouble of creating a compliance plan but doesn't follow it, the best case scenario is that employees take it as a sign that compliance isn't important, which can make a practice less compliant. Worst case scenario is the practice is investigated and investigators use the compliance plan as evidence that the practice knew it was breaking the rules.

Also, to Amyjph's points that practices need a professional's help and there's more to compliance that coding and billing: Privacy and security compliance must be part of every practice's compliance plan, or a separate compliance plan.