The government has not yet issued specific guidelines for physician compliance with Medicare and Medicaid billing, but HHS' inspector general's office last month began soliciting interest in them. HHS has already issued proposed or final guidelines for hospitals, clinical laboratories, Medicare HMOs and third-party billing agents.
In his MGMA presentation "Compliance 201: Implementing a compliance program" at 10: 45 a.m. Tuesday, Oct. 19, Howard Tepper, director of administration for the department of medicine at Newark-based New Jersey Medical School, will discuss the importance of developing a compliance plan and the eight elements to include.
Physician groups should review guidelines the inspector general has outlined for healthcare groups, especially for third-party billers, which are the most relevant, Tepper says.
Compliance plans are important because they help fulfill the practices' legal duty, may mitigate sanctions imposed by the government and payers, may catch and correct many billing and coding errors, and prevent whistleblower lawsuits by allowing people to air concerns within a practice.
An effective compliance plan can solve common physician billing problems, including documentation of procedures and demonstration of medical necessity, Tepper says.
A compliance plan requires a statement of goals; compliance oversight by an individual with authority in the practice; compliance guidelines that are specific and reflect the environment and procedures of the practice; an implementation plan, which can include a timeline, education and training; internal reviews and monitoring; reports of possible issues; and ongoing assessments. In his presentation, Tepper will discuss how medical groups can customize each element to their practices.
Also important is individual physician buy-in during development and buy-in of the final compliance plan. "Education of physicians must be concise enough to hold physicians' interest and detailed enough to go over all the regulations," Tepper says.
In the discussion, Tepper will share examples of practices' successes and failures in developing compliance programs.
Also at the MGMA conference, Tepper will hold an advanced session on compliance to discuss the effective implementation of the plan.
"Having a compliance plan that's not implemented is probably worse than not having one at all because you're showing to the outside world that you know it's important, but you never got around to doing it."