Delegation of Duties: It will be necessary to appoint a Compliance Officer who is qualified to oversee a healthcare compliance program. If you do not have an employee in your organization with such training, we have provided, and make available additional, resources that will prepare the appointed individual to assume such a role.
1. Compliance Officer: The individual appointed must be someone who refuses to compromise the quality and integrity of the compliance program. Policies pertaining to billing, coding, documentation, etc. should be viewed as mandatory, not optional!
2. Compliance Committee: Once your Compliance Officer is appointed, it will be necessary to determine what departments within your practice should be represented on a Compliance Committee to which the Compliance Officer will report. Frequently, providers mistakenly conclude that the practice consists of only one department. Rarely would this be the case.
Most practices will have, if nothing else, the following: (1) record keeping; (2) billing; (3) collections; and (4) production. Although one individual may wear hats for each department, it is best to consider these departments as discrete entities. This permits more effective management and analysis of your overall practice.
Compliance Manual: The Compliance Manual we have prepared addresses areas of exposure to which attention must be directed to attenuate (i.e., lessen) the exposure arising in each area. This is one of the most critical areas of any compliance program, and should not be given short-shrift.
Employee Manual: We have also provided an Employee Manual in which examples of employees’ duties and responsibilities are provided. It is recommended that the manual be tailored to the individual practice. While the duties and responsibilities included pertain to the principal areas of most healthcare practices, undoubtedly your practice has one or more unique areas that would benefit from slight modification of this manual.
Vendor/Agent Contracts: We have also included sample contracts to be used when working with vendors, independent agents, and licensed providers who are not employees of your organization.
Hotline: We have provided Hotline protocol, intended to provide a viable reporting mechanism for concerns/complaints concerning the organization’s practices. This protocol is effective in providing a reporting mechanism for concerns/complaints arising either internally (i.e., employees) or externally (e.g., patients, insurance adjusters et al.).
Education: The policies/procedures contained in the manual serve as an excellent educational tool for all employees, agents et al. However, to be effective, as is true for all education, it is necessary for those policies and procedures to animate those with whom they are shared. Merely having a dormant document in which such policies/ procedures are contained will not accomplish your intended goal of developing a vibrant bona fide healthcare compliance program.
Disciplinary Procedures: We have provided a guide to Disciplinary Procedures, applicable to both licensed and unlicensed employees. It is important to bifurcate these disciplinary procedures to ensure licensed providers that they are the individuals to whom boards of examiners will look for accountability, to whom law enforcement will look as the instigator of abusive and unnecessary procedures, and to whom governmental agencies will address inquiries into questionable/unusual practices. Unlicensed individuals must realize that their activities may also result in the accrual of personal criminal liability. Neither licensed nor unlicensed individuals are immune from prosecution. I was involved in one investigation in which a provider whose name was affixed to billing statements had been dead for more than six months, and the office manager’s sentence was actually longer than the doctors’.
Exit Interview: We have provided an Exit Interview form, as well as procedures to follow when employees sever their employment relationship, whether it be voluntary or otherwise. Failure to perform this procedure may result in many unnecessary claims (e.g., wrongful termination, “whistle-blower” actions, etc.) and prove extremely costly.
About the Author:
Dr. Tom Rhudy is licensed as both an Attorney and Doctor of Chiropractic in the states of Texas and Missouri. While serving as both an Attorney and Doctor of Chiropractic, he has worked closely with law enforcement, insurance carriers, administrative agencies, the FBI, US Attorney's Office, the US Postal Inspector's Office, and healthcare providers in the prevention, investigation, and prosecution of healthcare fraud.
For the past 20+ years he has devoted most of his efforts toward educating and assisting providers in the development of healthcare treatment and compliance programs and prevention of healthcare fraud and abuse, making every effort to improve the quality of care and representation provided to patients.
To obtain assistance in developing an efective healthcare compliance program, you may check us out here:
http://www.HealthCareComplianceTraining.net
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