ASC’s specialty, payer and physician mixes, so your findings will provide an accurate representation of your facil- ity’s overall caseload.

When coders do not meet the 97 percent accuracy threshold, additional training should be provided. Those who score in the low to mid-90s might only need to brush up on a single issue, while individuals who score closer to 80 percent might require supplemental training. Such continuing education is available online and at hospitals, local tech schools and universities. Coding certifications are available through a variety of accreditation bodies. ASCs with multiple specialties face a more significant challenge. In those centers, staff must be trained on each specialty to ensure that all procedures are being coded correctly to decrease denials and maximize reimbursement.

Legal Ramifications ASCs must navigate a dense regula- tory thicket of state, local and fed- eral requirements that affect both clinical and administrative opera- tions. The fines for infractions—and the legal costs associated with resolv- ing them—can be severe. For exam- ple, the US Department of Health and Human Services’ Office of the Inspec- tor General (OIG) in 2014 forced a California acute care hospital, Tulare Regional Medical Center, to give back $180,000 in Medicare payments for failure to comply with the agen- cy’s billing rules. Other providers have faced a simi-

lar fate. In the past decade, the OIG has uncovered widespread coding compli- ance issues in ASCs across the US. In 2010, federal auditors released a report estimating that Medicare contractors

overpaid ASCs by $6.6 million because of complex billing issues, which the OIG attributed to a lack of education among ASC administrative staff. Unfortunately, there is no simple solution for addressing all of the cod- ing compliance issues that might affect an ASC’s profitability. ASCs that imple- ment best practices, coder education and the right systems and processes, however, can minimize compliance risks, boost profitability and create the long-term growth necessary for an ASC to reach its full potential.

Jessica Edmiston is the vice president of performance review and Lori Samii is the vice president of marketing at National Medical Billing Services in St. Louis, Missouri. Write them at jessica. and

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