When beginning your first practice, establish a compliance program early to save yourself an audit later.
On an initial patient visit, one of the first things you do is establish a baseline: a virtual or literal snapshot of “where they are now” that you can measure progress against. This is both for your own purposes and to provide proof of progress in your documentation.
Your practice’s compliance health— and any degree of risk to which you might be exposing your business—is no different. If you don’t know where you are now in terms of Office of Inspector General (OIG) or HIPAA compliance, it’s a challenge to measure and track progress toward your ultimate goal: bringing your practice into compliance and into a zone of relative safety.
The first quarter of the year is a great time to conduct a baseline audit review before beginning any compliance program or installing compliance measures, both critical for practice compliance health.
Establish a baseline audit
Where possible, a certified consulting firm should be retained to provide initial and annual baseline audits for all providers, preferably under client-attorney privilege. A proper baseline practice audit should include the following items:
- An audit of a minimum of 10 charts per provider for documentation, coding, and billing, as well as adherence to usage guidelines.
- A baseline coding audit evaluating monthly code usage for at least the prior 12 months. Comparative analysis will include a review of evaluation and management (E/M) coding; chiropractic manipulative treatment (CMT) coding; modality and procedure coding; and any other ancillary services provided to patients. This review should be conducted for each physician in the practice.
- A review of existing policies and procedures installed in the practice to assess what’s in place and what needs to be added.
- A baseline audit of your practice’s internal systems, such as:
- New patient processing systems
- Documentation system
- Financial department systems for third-party insurers and patient billing and collections
- Patient case management system
- Marketing systems
- A brief review of your existing HIPAA compliance program for privacy and security, your OSHA compliance, and clinical laboratory improvement amendments (CLIA) compliance, if applicable.
- An assessment of your state-specific licensing, advertising, marketing, and advertising descriptive titles to ensure adherence to regulations and laws. This includes letterhead, business cards, signage, etc.
- Validation of all licensed employees’ status and non-exclusion from federal or insurance programs. This should include business licenses, professional licensure and certifications, and appropriate local tax licenses.
- Analyze any third-party contractual obligations and agreements to insure full compliance with your obligations and expectations.
The importance of a compliance program
All the above reviews are important and necessary when beginning a compliance program. They allow you to spot the deficiencies and weaknesses inherent in a system with human beings in it—i.e., a system vulnerable to human error, with a reasonable expectation that oversights and blunders will occur.
A thorough and up-to-date compliance program isn’t just required by regulation. It also helps you keep those inevitable mistakes to a minimum, with outlined action steps to correct them when they occur.
Kathy Mills Chang is a Certified Medical Compliance Specialist (MCS-P) and Certified Chiropractic Professional Coder (CCPC), and since 1983, has been providing chiropractors with reimbursement and compliance training, advice, and tools to improve the financial performance of their practices. She leads a team of 20 at KMC University, and is known as one of the profession’s foremost experts on Medicare. She or any of her team members can be reached at 855-832-6562 or info@KMCUniversity.com.