Third-Party Billing Company Compliance in 2014 TEN TIPS TO CONSIDER hat I am about to say probably will not come as a surprise to many of you. In order for a compliance plan to be effective, it must become an integral part of your billing organization. It cannot lie dormant until an auditor shows up or a violation occurs. rather, by applying the plan’s provisions regularly, you can achieve active compliance with applicable statutory and regulatory requirements. adherence to a well-designed compliance plan can streamline your billing company’s business operations, reduce the likelihood of a statutory violation, help mitigate any damages resulting from a breach, and serve as evidence that your billing company is doing its best to fully comply with the law. Indeed, when compliance becomes part of your daily culture, your billing company will achieve maximum results and rewards. as you are well aware, compliance plans and programs are not a “one-size-fits-all” solution. In order to be effective, compliance plans must be tailored to suit a billing company’s unique attributes, taking into account its capabilities and any company-specific risks that may exist. although a personalized approach is needed when developing and implementing an appropriate plan, there are a number of fundamental points that third-party billing companies should take into account when reviewing their compliance efforts in 2014. listed below are ten compliance tips you should consider. COMPLIANCE TIP #1: get back to basics: develop, implement, and follow an effective compliance plan. Hopefully, your billing company has already implemented an effective compliance plan. If you do not already have a plan in place, it is imperative that you develop and commence one immediately. To the extent that you have already initiated this process, do not assume that it is still current. Billing companies should review and revise their plans on an ongoing basis to ensure any new risk issues have 24 HBma BIllINg • maY. juNe.2014 been identified and taken into consideration. as set forth in the Department of Health and Human services (HHs) Office of Inspector general’s (OIg) 1998 publication titled “Compliance Program guidance for Third-Party medical Billing Companies,” the government has long viewed billing companies as an essential component of the compliance process. Healthcare providers are relying on these billing companies to a greater degree in assisting them in processing claims in accordance with applicable statutes and regulations. The government has long noted that providers often rely on the advice they receive from their billers. as a result, HHs- OIg expects third-party billing companies to take an active role in their client’s compliance process. a third-party billing company should look at its current practices and ask, “are we taking any affirmative steps to help better ensure that the claims we are processing are accurate and qualify for coverage and payment?”1 Put yourself in the shoes of an auditor or investigator. If a provider’s billings are audited, can you, as the provider’s billing company, demonstrate that you actively worked with that client to help ensure that the claims you processed were accurate? The government considers compliance program guidance to third-party medical billing companies particularly important in their efforts to combat healthcare fraud and abuse. Further, because individual billing companies may support a variety of providers with different specialties, billing companies should coordinate their compliance efforts with their providers. COMPLIANCE TIP #2: Carefully screen your employees, contractors, and business associates. Third-party billing companies must realize that the screening of new employees is not merely a provider’s responsibility. Billing By Robert W. Liles, Esq. W
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