INSIDE - Health Care Compliance Association

Sharon Hoyle
tion as Executive Director and CFO.
November 2003
16
DT: What are your duties as
Compliance Coordinator? How does
your position interact with the
Compliance Officer?
SH: I am responsible for all aspects
of program operations, which include
everything from training and education
to preparing and presenting reports to
the Board. Andy provides general oversight
and we meet regularly to discuss
any issues that are either in the process
of being resolved or have recently surfaced.
DT: What external resources have
you found to be helpful in your day-today
compliance activities?
SH: There are two resources that I
rely on and find helpful. One is our
HCCA membership. Each time I
attend an HCCA event, read an article
in Compliance Today or The Journal
of Health Care Compliance, or network
with other members, I am reminded
that our company is not the only one
facing the challenges that health care
compliance can impose on an organization
and there are other organizations
with challenges very much like ours.
The value of being part of this organization
comes from the tremendous
amount of information available
through these resources, which makes it
easier to conquer these challenges.
Another resource that I rely on is
our outside legal counsel. For about
three years, I have engaged the same
health law firm and find them to be
very responsive and in tune with compliance
issues that are common in
physician practices. This long-time relationship
has a lot of value to our company
in that the attorneys are familiar
with our corporate structure and can
respond to our questions with sound,
practical advice. Although they are not
local, they are accessible and so it is
good to know that when I have a question,
I can easily get an answer with a
quick phone call or email.
DT: Do you provide annual training
for your physicians and staff? If so, is
the training mandatory and what topics
are included?
SH: Training on our Code of Ethics
is conducted annually during the first
quarter. Every member of the organization
receives a copy of the Code of
Ethics and is required to acknowledge
in writing that they have read, understand,
and agree to abide by our Code
of Ethics. I also present an overview of
our compliance program to physicians
and employees hired throughout the
year. During the overview, the Code of
Ethics is discussed and the physician or
employee must provide written
acknowledgement of our Code of
Ethics.
Focused training on fraud and
abuse, coding, local medical review
policies, ABNs, etc. is provided
throughout the year and anyone directly
involved in coding and billing is
expected to participate. The training
environment is relaxed and informal
and a variety of formats ranging from
department meetings to Web casts are
used to communicate information. I
think the most successful format has
been computer-based training (CBT).
In 2001, we began using the CBT
modules provided by the Centers for
Medicare and Medicaid as an option
for training. This proved to be successful
in two ways. First, it is cost effective,
and second, it is convenient for
Health Care Compliance Association • 888-580-8373 • www.hcca-info.org
DEBBIE TROKLUS
employees unable to leave their workstation
for an extended period. Given a
deadline for completing the CBT, these
employees can work on the assigned
modules at their own pace and remain
in their department. Our company
intranet is also used to communicate
important information like new or
revised compliance policies and procedures,
changes in Medicare policy, and
Medicare program exclusions.
DT: Do you conduct compliance
audits/reviews? If so, how many services
are reviewed per physician?
SH: Compliance audits are a normal
part of operations and the physicians
look forward to the feedback. Generally,
when auditing E/M coding, I will
look at 10 encounters per physician
annually and about 30 encounters for
new physicians to establish a benchmark.
The number of services reviewed
can change depending on procedure
code utilization and previous audit
results.
DT: How do you determine what to
include in your audit plan each year?
SH: The audit plan is determined by
a couple of things. One is the OIG’s
Work Plan. Each year the Work Plan is