DOING BUSINESS
and refund overpayments promptly (per regulatory requirements); and
■■
knowing misuse of provider iden- tification numbers, which results in improper payment, and falsely using a patient’s identification number to bill procedures that were not provided.
Patient Confidentiality
Although not directly related to reim- bursement, another important area that needs to be constantly monitored for compliance is the maintenance of confidentiality of patient informa- tion and records. Staff members need to be aware of the proper handling of protected information, including tele- phone, email and written and in-per- son conversations that might be inter- cepted or overheard by another party. When claims are submitted or in cor- respondence with payers via the Inter- net, the center or the outsourced billing company must have secure connec- tivity in compliance with the Health Insurance Portability and Account- ability Act of 1996 (HIPAA).
Importance of Compliance Program and Employee Education Whether your ASC is relying on inter- nal or outsourced revenue cycle man- agement, it is vital that you or your billing company have a written revenue cycle compliance program in place. It should be enforced and updated regu- larly to remain current with federal and state regulations and third-party payer contract guidelines. Fundamentally, revenue cycle compliance programs are designed to promote, prevent, detect and resolve occurrences that do not conform to federal and state law; federal, state and private payer health care program requirements; and your center’s busi- ness office policies. Specifically, your compliance program should provide guidelines to both your ASC’s man- agement team and business office staff that support efficient and compliant management of your ASC’s revenue
cycle. It also should serve as an inter- nal control in reimbursement and pay- ment areas, especially where claims and
billing operations
can be the
source of fraud and abuse. The most practical way of ensur- ing that your business office staff or outsourced billing team understand and remain compliant with regulatory requirements is a properly established education program. This should include compliance in-services for revenue cycle staff members at the time of hire and annually thereafter or when there are changes/updates to regulations. It also is incumbent upon management to provide billing staff with up-to-date revenue cycle reference books and/or computer programs in the ongoing pur- suit of compliant reimbursement.
Benefits of Compliant Revenue Cycle Management It is your ASC’s responsibility to pro- vide ethical leadership and ensure that adequate systems are in place to pro-
mote and facilitate the ethical and legal management of your revenue cycle process. Whether your coding, bill- ing and collections are performed by in-house business office staff or out- sourced to a revenue cycle manage- ment company, your ASC’s manage- ment staff and, ultimately, your ASC’s governing body are responsible for the center’s compliance with federal and state regulations. Noncompliance can expose your center to civil damages and penalties, criminal sanctions and administrative remedies, such as Medi- care/Medicaid program exclusion. Every center’s goal is to be finan- cially successful while maintaining a good moral reputation with patients, the community and federal, state and third-party payer organizations. Integ- rity and compliance are the stepping stones to achieving these goals.
Caryl Serbin is the president and founder of Serbin Medical Billing in Fort Myers, Florida. Write her at
caryl@serbinmedicalbilling.com.
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