A Day, Week, Month, and Year in the Life of Your Compliance Officer
COMPLIANCE
Kathy Mills Chang
MCS-P, CCPC, CCCA
Unfortunately, many chiropractic practices do not have adequate compliance programs. Either they have nothing in place or they have merely created a binder or two containing a few templated forms that were pulled from the Internet. Healthcare attorneys declare that, although the law requires compliance programs, it is almost better to have nothing than to have a manual that sits on a shelf collecting dust. Trust us, you should not have nothing!
Appointing a compliance officer (CO) is critical for ensuring that your compliance program is viable. The duties and responsibilities of the practice’s CO are very important. The obligations of the CO do not have to take a significant investment of time if they are handled systematically and on a schedule. Naturally, the time demands will vary according to the size of the practice, but a typical chiropractic practice will need a CO’s investment of between 12 to 24 hours per year once the program is up and running. The duties can be spread out over the year in oneto two-hour monthly increments. Build that time into your schedule on set days at set times wherever possible. This fact sheet will outline the most important duties—broken down by frequency—as a guideline for time management.
Daily Duties
Ongoing policy and procedure monitoring: The most important daily duty is simply keeping your eyes open. Once your compliance program is operational, it’s important to continually review the activities, scripting, and other events of the practice to ensure compliance. As new issues come up, ask yourself if a policy exists to address that particular situation, and if not,
see that one is written and disseminated to the team. When a procedure doesn’t appeal' to be working or repeated errors take place, review the process, identify the breakdown, and rewrite or assign the review of the written procedure. Remedial training may be necessary.
Weekly Duties
Weekly review of reported compliance concerns: If you have a Dropbox or other anonymous reporting method for compliance communication horn team members and patients, be sure to check it at least weekly and respond to any reported concerns.
Incorporate ongoing compliance training in weekly team meetings: If your team meets weekly, devote a segment of the team meeting to a review of compliance-related findings from spot checks, audits, or other compliance activities. If eveiything is going well, prepare a compliance-related training tip or “did you know?” that would be interesting to the team and further the ongoing compliance knowledge of the practice.
Monthly Duties
Schedule these about the same time every month, such as spot-check audits are conducted on the third Thursday, etc.
Monthly compliance report and meeting with the doctor/owner/administrator: Conduct a monthly compliance meeting with the doctor or administrative supervisor to report on the previous month’s compliance activities. Use an agenda template to prefill the report with items listed for discussion and to record minutes of the meeting. This agenda and written
report will serve as your copy of the meeting minutes and should be included in your compliance policy manual.
Randomly spot check/audit one to four daily notes per provider: While a complete audit may not be necessary every month, randomly pulling charts and spot-checking dates of service is a great way to stay on top of little problems before they become big ones. Use your compliance reporting meeting to share concerns with the doctor/owner who can assist you with arranging remedial training time if necessary. Be sure that any concerns are monitored through correction and training.
Review explanations of benefits (EOBs) for denials, proper posting, and handling: Randomly select a handful of EOBs thr oughout the month to ensure that they have been posted properly; that denials have been handled correctly; and that issues have been resolved. These findings may result in the necessity for additional training for the team member(s) responsible. Report to the doctor/owner in your monthly meeting about what you have found.
Annual Duties
Annual duties can be conducted throughout the year on a scheduled basis. As you set your annual compliance-duty calendar, spread out the items to accommodate the workflow of the practice.
Complete an audit of five to 10 charts per provider and specialty: Your full baseline audit of each provider may indicate necessary corrections and items that require additional training. These adverse findings will drive your selection of training for each provider and team member.
Perform a complete coding audit: At least annually, do a complete audit of all coding in the practice. Look at every code billed by the practice and its frequency per month. Make certain that the practice understands what constitutes medical necessity for each code submitted.
Review all provider contracts with insurance carriers: In
order to conduct an annual review of provider contracts, it will be necessary to analyze medical review policy and contractual obligations set forth in the actual contract, and to ensure that there have been no changes in language or specific rales that the doctor must follow.
Review existing policy and procedure for accuracy, completeness, and relevance; update where necessary. At least annually but ideally on a continual basis, review the entire compliance program, including both policy and procedure, for relevance and that it is properly scaled to your needs. Any policy or procedure that needs to be updated or revised should be pulled and worked into your schedule. Remember, you can delegate these updates to appropriate team members and then approve the final document.
Hold an annual compliance meeting with the team to
review and renew the practice’s code of conduct and update as
appropriate. Hold an annual mandatory compliance training program. In the minutes, confirm the attendance of each person with his or her signature. This training could include annual updates on audits, error rates, news in the profession, etc. Updating the team about any major changes or additions to your compliance policy would also be an appropriate component of this training. The training could be conducted externally by appropriate sources, but be sure to fill in the team training log and include it in your compliance policy manual.
Confirm that all key team members have completed annual training related to then duties and include CE credits where required. At least annually, schedule appropriate external and continuing-education training for all key team members. Look for coding, billing, and documentation training held by your state association or other groups such as KMC University. Always complete the training logs for each training that is attended and keep a copy of this log in your compliance policy manual.
As-Needed Duties
Situations will always come up that are not part of your regular compliance calendar of activities. Handle these on an as-needed basis.
Initial compliance training for new team members:
As new team members are added, they must take part in compliance-related training. Those in the billing and collections area have a greater responsibility and therefore must have compliance-related training sooner than others. Make sure that your initial employee-training checklist includes these important tasks. Sign off when complete and include in the employment jacket.
Ongoing and remedial training based on audit findings or spot-check findings: As you find errors and other oversights in your spot-check training, remedial training or collection should take place immediately. Record these and document your findings and training.
Ongoing casework for compliance incidents: As compliance incidents are brought to your attention, such as overpayments, billing errors, etc., they must be handled immediately. The ongoing work to resolve incidents must be handled at the time of discovery.
By following the guidelines outlined here, your practice can meet the requirements of compliance in a timely, organized, and well-managed approach.
Kathy Mills Chang is a cert~Jied medical compli ance specialist (IvICS-P), a certified chiropractic professional coder (CCPC), and certified clinical , chiropractic assistant (CCCA). Since 1983, she has provided chiropractors with reimbursement and corn pliance training, advice, and tools to increase revenue and reduce risk. Kathy leads a team of 20 at KMC University and is considered one of our profession foremost experts on Medicare documentation and compliance. She or any of her team members can be reached at 855-832-6562 or info(ã~,kincuniversitv.com.
