The business of diagnostics and health systems gets more complicated all the time, and the increasing complexity of your compliance obligations can at times seem overwhelming.
You know that your compliance obligations start with meeting the requirements of the Federal Sentencing Guidelines for an effective compliance program. You are aware that means that you need to exercise diligence to prevent and detect criminal conduct, and to promote an organizational culture that encourages ethical conduct and a commitment to compliance with the law. You already have a written compliance and ethics program including standards of conduct, with an executive with the right background designated as responsible for the program, with appropriate resources, probably including one or more committees to help your compliance team manage your compliance program. You train your employees on compliance and you maintain communications, including a hotline for anonymous reporting of compliance issues. You monitor and audit your compliance activities. You maintain disciplinary guidelines and respond to and correct compliance problems.
You understand that the Department of Health and Human Services has issued its own guidelines, and through corporate integrity agreements and other communications, has described its own expectations for an effective compliance program. You recognize that some state Medicaid programs require you to maintain an effective compliance program, and that your activities may involve other state and federal compliance requirements. You recognize that you have to comply with the security and privacy requirements of HIPAA, and that there are other security and privacy requirements applicable to your business. You have created the right “tone at the top”; you monitor the “mood in the middle” of your organization; you discuss compliance in your executive meetings and with your board of directors. You review the risks facing your organization, and that review guides your compliance efforts. You are aware that any misstep may result in fines, penalties, and other adverse consequences to your organization, its executives, and other personnel.
But things keep changing. How can you keep up?
Expect your vendors to do their share to help your compliance efforts. Do you use revenue cycle management software that makes your compliance activities easier? Does it maintain a first-rate, highly secure environment? Does it include data sources that update key codes and billing information to get your claims processed correctly and in compliance with applicable requirements? Does it provide automated support for required documentation, logging, and recordkeeping? Is it configured to comply with the ever more restrictive rules around managing co-payments and deductibles? Have you considered outsourcing all or a portion of your billing activities to address the risks of fraud, waste, and abuse when your own employees manage the entire process?
Maybe it’s time to review your revenue cycle management software, and billing and collection activities, and ask are they helping your compliance program, or just creating more challenges?