Steven Baruch - Health Care Compliance Association

More documents

Recommendations

Info

Managed Care Compliance Conference February 6–8, 2011 Scottsdale, AZ | FireSky Resort HCCA’s Managed Care Compliance Conference provides essential information for individuals involved with the management of compliance at health plans. Plan to attend if you are a compliance professional from a health plan (all levels from officers to consultants), in-house and external counsel for a health plan, internal auditor from a health plan, regulatory compliance personnel, or managed care lawyer. learn more at www.hcca-managedcare-conference.org Improving Governance Practices Audit & Compliance committee conference February 7–8, 2011 | Scottsdale, AZ Learn more at www.auditcompliancecommittee.org This conference is designed for board members and members of a board audit and/or compliance committee of not-for-profit health care organizations. Compliance officers may attend with their board member(s). CEOs, CFOs, and other senior officers are also welcome to attend. The Audit & Compliance Committee Conference is jointly sponsored by the Health Care Compliance Association (HCCA) and the American Hospital Association’s (AHA) Center for Healthcare Governance December 2010 40
Federal medical record requests: Setting up a RAC & CERT Response Team ...continued from page 39 documents from the chart, routing the chart to the next level (i.e., a clinical leader for clinical data verification), and receiving, after final approval for copying and certified mailing, the various chart documents selected to fulfill the official MR request. This person, if he/she is responsible for opening/routing the practice mail, will also direct all post-fulfillment adjudication notices to the clinical director or practice manager for appropriate follow up. Obviously, if other persons are responsible for various duties along the way, then those persons would be injected into this process at the appropriate points. Alternates should be appointed in the case of staff vacations, absences, etc. This is a highly flexible arrangement of roles and responsibilities, and it can be constructed in many different ways, depending on the size, staffing, and physical location(s) of its various team members. decisions, which should be carried out if the encounters in question have been misjudged or assessed prematurely in some crucial way (e.g., specific documentation was not available and therefore was left out of the original audit package, a signature log or physician attestation is needed to authenticate the documents after-the-fact, etc.) The various audit types (e.g., CERT, RAC) will lumber under different assessment rules and appeal rights for the provider; the facility and practice leaders should be familiar with these rules and rights. Negative impact on revenue should be viewed with a critical eye and questions asked, such as: Are the MR requests resulting in denials with attached repayment demands for simple services that, if documented with higher quality levels or coded more accurately, would be approved and paid Opportunities for operational improvement and growth may not always be obvious, but even minor documentation and/or coding changes can potentially save the facility or practice thousands of dollars annually. Performing impact analyses Post-audit analysis of each case must be performed; it is essential that the facility, clinic, or physician practice leaders view each final ruling by the oversight entity (e.g., CERT, MAC or RAC) as an opportunity for growth and possible restructuring or clarification of duties. This can include necessary modifications in documentation (e.g., EHR training, documentation and/or dictation techniques, establishing process points to be followed, and/or enhancing data integrity/quality), coding education and fortification, improved billing standards, or all of these actions. This might also include opportunities to appeal the The ubiquitous and ever-growing number of federal MR requests sent to providers should be treated the same way an IRS tax audit would be treated: with great care, attention to detail, and inspection of all documents to be forwarded. Once the requested records have been mailed to the entity, providers should anticipate receipt of final results on every case and perform appropriate follow up actions to correct functional inadequacies in administration, clinical operations, or coding and billing. n 1 CMS: Medical Learning Network: MLN Matters SE1024 “Recovery Audit Contractor (RAC) Demonstration High-Risk Vulnerabilities – No Documentation or Insufficient Documentation Submitted” revised July 14, 2010. Available at http://www.cms.gov/mlnmattersarticles/2010mman/itemdetail.aspitemid=CMS1237489. The Health Care Compliance Professional’s Manual With Annual Subscription Service • Hard-copy subscribers receive quarterly updates • Internet subscribers receive updates as soon as they are issued Published by CCH and HCCA Members: $369/year Non-members: $409/year The Health Care Compliance Professional’s Manual gives you all the tools you need to plan and execute a customized compliance program that meets federal standards. Available via print or the Internet, the Manual walks you through the entire process, start to finish, showing you how to draft compliance policies, build a strong compliance infrastructure in your organization, document your efforts, apply self-assessment techniques, create an effective education program, pinpoint areas of risk, conduct internal probes and much more. To order, visit the HCCA website at www.hcca-info.org, or call 888-580-8373. Health Care Compliance Association • 888-580-8373 • www.hcca-info.org December 2010 41
Page 1 and 2: Volume Twelve Number Twelve Decembe
Page 3 and 4: Publisher: Health Care Compliance A
Page 5 and 6: for the nurse with the bad back, th
Page 7 and 8: Mobility disabilities: A technical
Page 9 and 10: RACs are coming to Medicare Advanta
Page 11 and 12: an attestation statement for the pu
Page 13 and 14: Social Networking John Falcetano Ed
Page 15 and 16: SB: I am the first full-time, dedic
Page 17 and 18: If you have any questions that you
Page 19 and 20: I called Joe Murphy, and before I t
Page 21 and 22: Once these steps are completed, the
Page 23 and 24: of 2010 (PPACA) and the Health Care
Page 25 and 26: 100% Why is Compliance not a part o
Page 27 and 28: Routine meetings should be set up s
Page 29 and 30: COMPLIANCE 101 Stark and academic m
Page 31 and 32: total compensation of the referring
Page 33 and 34: teaching hospitals, medical schools
Page 35 and 36: providers who participate in the Me
Page 37 and 38: Health Care Compliance Association
Page 39: ecognized now by the federal govern
Page 43 and 44: medication and services previously
Page 45 and 46: individual accountability provision
Page 47 and 48: created inappropriate financial inc
Page 49 and 50: New HCCA Members n Coquette O’Rou
Page 51 and 52: • Internal Audit • Litigation S

Steven Baruch - Health Care Compliance Association

You also want an ePaper? Increase the reach of your titles

Delete template?

Save as template?