Improving Your Reputation: How to Help Your Healthcare Organization See the Compliance Department in a Positive Light

When the compliance team visits another department, staff responses are usually the same: we must have done something wrong.

This isn’t the response that you want. The compliance department and staff should be seen as approachable, working in a collaborative fashion to make the organization more successful. If the compliance department only comes in to run audits and give “constructive” feedback, then compliance will quickly become known for negativity and criticism.

Collaboration

It is important to collaborate with other departments and incorporate a holistic organizational approach. This means valuing what other team members have to offer with regards to compliance in the organization. It can be easy for compliance professionals to make black or white statements regarding compliance with a specific regulation or policy. After all, it’s there in writing — in black and white.

But, other teams can sometimes bring to light another perspective. There may be gray areas in the written requirements or overall process and addressing these could benefit the organization without compromising compliance.

Or, compliance professionals could demonstrate openness to evaluating how requirements and regulations are impacting specific operational workflows. For example, when evaluating a compliance process for telehealth visits related to obtaining consent, the operations leader should be given an opportunity to work with compliance in developing the process.

In-Person Education

One approach to improving collaboration with other departments is to conduct in-person education and question and answer (Q&A) sessions. Ask all department leaders if you can have ten (but no more than fifteen) minutes at their next staff meeting to introduce the compliance team and to solicit compliance-related topics and questions. Before the meeting, make sure to get the department leader to provide two to three compliance-related topics that would be of interest to their team. Prepare a short slide presentation to use in the meeting — typically, one slide per topic and one Q&A slide at the end.

During the meeting, make sure to leave at least five minutes for compliance Q&A. Listen to the staff questions and solicit information on challenges or knowledge gaps related to compliance, so follow up can be done with the that department or team.

Follow-Up Education

Follow up should be timely (within three to four weeks) and can be done a few different ways: short videos, posts on the internal intranet or website, email education, or additional in-person follow up education. There are several excellent (and free) applications available online where you can create short, two- to three-minute compliance videos that can then be distributed to staff.

Follow-up education could also be done by email if the topic and question and answer lends itself to an email response. For example, if staff ask a question about HIPAA’s application to texts or emails, it would be fairly easy to find a one-page summary on the application of HIPAA to texts and emails and attach that to an email.

Volunteers

Another way to improve collaboration would be to have compliance staff volunteer to participate in organization committees not directly related to compliance. For example, compliance professionals could join the policy committee or the activities committee. In this way, the compliance team can develop positive relationships with others in the organization, in an open and approachable way.

Practice Tip:

  1. Reach out to at least 3-4 departments before the end of the year to schedule and conduct in-person meet and greets with a focus on compliance education.
  2. Utilize services such as youCompli to stay current on compliance topics and regulations to present during your meet and greet meetings.

Denise Atwood, RN, JD, CPHRM
District Medical Group (DMG), Inc., Chief Risk Officer and owner of Denise Atwood, PLLC
Disclaimer: The opinions expressed in this article or blog are the author’s and do not represent the opinions of DMG.

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5 Payer Audit Errors Every Hospital Must Avoid

Most healthcare providers, from large hospitals to solo practitioners, experience an audit at some point. The scrutiny can unveil errors and violations, which can lead to hefty penalties.

The key to surviving a payer audit, with the least amount of frustration, is to avoid these five common errors.

1. Late Responses

Your deadline to submit relevant documentation begins upon receiving that payer audit request.

Payer audits may be requested by a private health insurance provider, through the Centers for Medicare and Medicaid Services, or both. While the origin of the audit request doesn’t matter, response time is essential.

Take all deadlines seriously, and if an extension is needed, ask for one, immediately. Missing deadlines can result in hefty fines and penalties.

Also, if the payer doesn’t provide a deadline with the request for documentation, it may be wise to ask for a date to submit information.

2. The Wrong Documentation

A common trigger for payer audits is improper documentation. As a healthcare practitioner, you must prove the medical necessity of each test or procedure used to diagnose and treat your patients.

Here’s the tricky part. Sometimes payers and providers disagree on what tests or procedures are medically necessary.

One way to mitigate this problem is to educate your staff on what services the payer considers medically necessary.

Another way is to clearly document the need for a particular procedure to treat or diagnose a patient.

The easiest way, however, is to ensure that authorization is received from the payer before rendering services.

3. Using the Wrong Codes

Incorrect billing and coding practices can raise suspicion of fraud, failed claims, or delayed reimbursement, and — you guessed it — payer audits. Providers and patients overpay a whopping $68 billion annually due to incorrect billing.

Coding systems developed by the American Medical Association and the Centers for Medicare and Medicaid are designed to streamline the billing process. Every medical procedure and service from ambulance rides to chemotherapy drugs to doctor visits are contained within coding systems such as the ICD-10, CPT, and HCPCS.

Studies show 80 percent of medical bills in the U.S. contain errors. This percentage can decrease by investing in annual updates of medical codes procedure handbooks and by steering clear of old and outdated codes.

4. No Self-Audit

One way to prepare for payer audits is to perform regular self-audits within your facility.  Internal audits are great for identifying and eliminating weak spots that can potentially lead to headaches down the road, like rejected claims and costly compliance failures.

One drawback is the strain on precious resources like time and personnel. You can get around this problem by hiring a third-party audit service. But then you have third-parties going through private patient information.

Another option is a software-based solution that provides 24/7 access to survey compliance data. Ideally, this software will provide automatic tracking of all documentation and decisions involved in the process of running your organization.

This ensures that compliance professionals can get immediate reporting on how well their team is doing, conducting audits more efficiently and effectively. It’s a time and cost-effective solution to hiring an outside third-party provider.

5. No Legal Help

Having a healthcare attorney in your corner can mean the difference between a smooth audit experience and an audit nightmare.

Here’s how a healthcare legal team can benefit your health practice:

  • Work intimately with your staff to analyze any risky billing procedures.
  • Challenge any demands from payers for overpayment.
  • Challenge any allegations of fraudulent billing practices.
  • Push back on any denied claims and the overuse of service claims.

Again, software is a useful tool to support your attorney’s work. A system that stores all compliance information, including payment practices, and has search capability will provide your legal team with the information needed to fight payer audit discrepancies when the time arrives.

Payer audits don’t have to be a nightmare. By being adequately prepared and vigilant, your next audit experience can be more streamlined and less stress-inducing.

Let us help you prepare for your next payer audit. Contact us today to learn how we can help your organization stay compliant in a sea of complicated healthcare payment regulations.

Audit Expectations and Challenges

When it comes to hospitals providing best-in-class health care, stress comes with the territory. From stabilizing trauma victims, to accurately distributing medications, to physicians and nurses working long shifts, increased demands are everywhere — including operations not directly involved with patient care. One demand that can turn daily routines completely upside-down and compound stress is an audit. A GRC compliance audit can be conducted internally by various hospital committees or externally, often by government-approved contractors.

Internal Audits

An internal audit seeks to determine if a hospital’s financial and operational controls, and their related policies and procedures, meet compliance and risk management demands.

Based on a hospital’s risk assessment, management develops and reviews the scope and goals of an audit. Running the audit is then delegated to a committee, with the most common committees focusing on:

  • Patient safety
  • Nursing staffing
  • Clinical quality
  • Medical staff

An internal audit involves interviews and evaluating personnel or procedures. Upon the audit’s completion, a report of its findings is prepared by the appropriate committee and shared with management. Corrective recommendations of action to any areas of noncompliance are collaboratively developed, and a finalized report is presented to the hospital’s board of directors, chief compliance officer, and audit and compliance committee.

The ultimate goal of an internal audit is to improve patient care. Who in a hospital wouldn’t want to improve it, right? But the truth is that an audit can diminish quality of care while it’s in progress. That’s because committees are often comprised of physicians, nurses, and technologists who are pulled away from patient-care responsibilities to work on compliance administrative tasks.

External Audits

According to a 2017 AHA report, four federal agencies — the Centers for Medicare & Medicaid Services, the Office of Inspector General, the Office of Civil Rights, and the Office of the National Coordinator for Health Information Technology — are the primary drivers of regulations and compliance costs across eight domains for hospitals:

  • Hospital conditions of participation
  • Billing and coverage verification requirements
  • Meaningful use of electronic health records
  • Quality reporting
  • Privacy and security
  • Fraud and abuse
  • Program integrity
  • New models of care

The frequency and pace of regulatory changes implemented by multiple federal agencies are dizzying. Hospitals are often required to comply with regulations in very short timeframes, requiring a significant investment of staff time and finances. What’s more, responding to multiple external audits increases administrative costs, and funds could be tied up in lengthy appeals processes contesting an auditor’s inappropriate determination.

External audits are conservatively estimated at $100 per hour. For example, consider the total costs of a HIPAA audit:

  • HIPAA Gap Assessment — Identifies gaps and provides remediation plans for those gaps
    (40 hours average, $24,000–34,000)
  • Full HIPAA Audit — Assesses hospitals against all the requirements in the HIPAA Security Rule
    (100 hours average, $30,000–60,000)
  • Validated HITRUST Assessment — Provides the most complete, certifiable framework for HIPAA to mirror PCI compliance (400 hours average, $100,000–160,000 — with costs much higher for larger organizations)

Protect Your Hospital

If your hospital is like most others, it’s spending too much staff time and money dealing with a blizzard of regulations and an avalanche of red tape. Fortunately, there are solutions. youCompli GRC risk management software monitors, reads, and translates complicated regulations into plain English. Our solution enables you to fully understand which rules are pertinent to maintaining compliance, further simplifying the auditing process. And it tracks everything, from end to end, making audits much less painful.

Learn how youCompli regulatory compliance management software protects your hospital.

74 Federal Healthcare Regulatory Changes in January 2019 Alone

Yes, 74!  Are you surprised? In recent months, we’ve noticed two themes that challenge everyone managing regulatory changes: First, regulatory changes are flooding into your organization in lots of different ways, to lots of different people; daily subscriptions, hospital associations, clinical associations, law firms, etc. This can be very chaotic. A compliance officer recently joked that she […]

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