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February 25, 2013
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The "Four C's" of Revenue Cycle Management (RCM): First: Compliance
PBN recently published a complete series of articles covering healthcare compliance, including a historical overview and legal map, guidance for developing an “effective” compliance plan, and a summary of what can go wrong in the current enforcement-oriented regulatory environment.
The upshot of all of that information is that now more than ever, it’s important to have all of your ducks in a row . . . everyone involved in healthcare, from small practices to large hospitals and the largest healthcare organizations, is now subject to healthcare regulations, including requirements for a written and “effective” compliance plan. CMS has also been cracking down on everyone from outright “crooks” who intentionally cheat the system, to people who just have sloppy billing practices.
How Compliance Fits in With the other C’s . . . Compliance is critical to every step in the medical billing process. As our “4 C’s” illustration shows, all of the C’s are interrelated. But Compliance overlaps the most with every other aspect of providing healthcare services: from how provider relationships are documented in contracts and payer enrollment, to documenting healthcare services, to accurately coding and billing for those services to collecting
Why you need a plan . . . Jud Neal, PBN President and CEO explains PBN’s reiterative “closed loop quality process” to PBN clients like this, “We may make mistakes, but when we do, we’ll tell you that we did: tell you exactly what happened, how we plan to fix it, then fix it and take preventive actions to make sure it doesn’t happen again.” That is a good general outline of an effective healthcare compliance plan. However, to sufficiently comply with the law (which can provide some immunity from personal and criminal liability and reduce or eliminate fines), you’ll need to develop yours according to OIG Guidelines and be able to prove your plan’s effectiveness.
It’s either about doing the least to comply with regulations, or it’s about doing the right thing.
Negative, Legal Requirement Compliance Focus: the focus here is on minimal regulatory compliance and doing the least possible to keep the organization out of legal and regulatory trouble and avoid taking on any undue risk. You draw up a plan because the law says you have to. You view the expense as a kind of license and a cost of doing business.
Positive, Business Practice Compliance Focus: Approaching healthcare compliance from this positive point of view means recognizing “compliance” measures as good for practitioners and for business. The focus here is on increasing quality and “doing the right thing.” Your efforts will blend both regulatory requirements and non-regulatory best practices. A complete plan combines OIG compliance requirements for a plan that . . .
. . . plus non-regulatory best practices applied within the context of a larger Quality Control Plan. This combined approach will also improve your billing and other processes to ensure the timeliness and accuracy of remuneration.
Resources . . .
. . . PBN is here to help. Contact PBN Business Development, 800.288.4901 or .
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Inside the
How to keep your picture off this page . . . Most of the people on the page started out with the intention of defrauding Medicare or Medicaid for personal gain. But, some of these fugitives and others charged with healthcare fraud probably thought they were working along, upholding the law in a legitimate healthcare business position and still ended up here. How could that happen? If you are in a position of responsibility and one of your reports (even unbeknownst to you) or a contractor such as your billing company engages in healthcare fraud, you may be personally and criminally liable.
How can you know everyone is on the up and up? The OIG and HHS now require even the smallest practices and clinics to have a plan in place that answers exactly that question (and several others, like how do you know all of your vendors comply with the laws? How will violations be reported? And what steps will you take to rectify noncompliant behaviors?). Compliance comes first among the “Four C’s of RCM” because you have to plan for it and build in answers to those questions every step of the way, from accurately recording and coding care delivery to revenue collection.
Need help getting started?
Call us.
We have an active compliance plan and can help you get started with yours.
— Jud
Jud Neal, PBN President & CEO
Visit us online at PBNMed.com
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