CODING COMPLIANCE SELF-EVALUATION

Yes

No

Not Certain

Do you conduct internal chart reviews?

Has your "superbill" been reviewed in the last six months?

Does your superbill reflect current CPT and ICD-9 with the correct definitions?

Do you routinely collect patient copays?

Do you always have the patient sign a "Advanced Beneficiary" Form in advance of a potentially disallowed procedure?

Does the practice demonstrate responsibility for educating all appropriate staff on coding?

Do your new patients sign an authorization to release information to insurance companies/Medicare along with assignment of benefits? Including your HIV patients?

Do your HIV patients sign an authorization to release (or not to release) medical information?

Do CPT/ICD-9 codes on your claim forms accurately reflect your medical record documentation?

Is a patient’s name and date of birth on every sheet in the chart?

Do the treating physicians always initial or sign the patient medical history form and each progress note or exam form?

Does Your Practice Need a Compliance Program?
       YES.

     What Are the Goals of a Compliance Program?

Although there is no current federal mandate to develop or maintain a compliance program in your medical practice, not having one places your practice in jeopardy. A full-blown compliance program requires financial and human resources and carries with it the burden of enforcement. Not having a program in place weakens your position to demonstrate good intentions during an audit.

• The government estimates $100 billion annually are paid in fraudulent claims.
  
• The government and its Operation Restore Trust has dedicated itself to recovering monies from incorrect Medicare claims.
  
• Penalties for fraudulent claims can be up to $10,000 per claim.
  
• 1996 government efforts recovered $43.2 million in inappropriate payments.
  
• The pursuit for wrongful payments is not going away.
  
• Having a program in place strengthens your defense if aberrant claims are uncovered.

• To prevent violations
  
• To detect violations
  
• To remedy violations
  
• To demonstrate good faith
  
• To assure quality practice performance standards
  
• To improve practice performance standards

A compliance program should be reflective of your practice. Buying an "off-the-shelf" model program will probably not fit the characteristics of your practice. A compliance program on your bookshelf does not make your practice compliant.

The Seven Elements of a Compliance Program:

1. Written standards of conduct
   
2. Identification of a compliance officer
   
3. Education and training of personnel
   
4. Procedures to effectively communicate or disseminate information
   
5. Monitoring and auditing to detect violations
   
6. Policies and procedures to enforce compliance and discipline wrongdoing
   
7. Policies and procedures to remedy wrongdoing