Physician compliance training a serious matter
Use personalized classes, chart audits
Compliance program directors at physician practices across the country take compliance training for physicians seriously.
In an informal poll, the vast majority of compliance professionals in academic and private practice reported that compliance training is mandatory for physicians.
Mary Ann Swann, MBA, FACMPE, CPC, director of compliance programs at Baylor College of Medicine in Houston, conducted the poll to find out what techniques other groups had found effective in implementing their compliance programs.
The 51 respondents representing 22 states reported:
• 92% of responding organizations provided compliance training to their physicians.
• 86% of the respondents reported that training is mandatory.
Some groups apply sanctions to physicians who don’t complete the training in a certain time.
Even if physicians delegate the activity of coding to their staff, they don’t delegate their responsibility for the coding, Swann pointed out in a presentation at the Medical Group Management Association, annual meeting in Atlanta.
"Physicians have to have an overview of codes submitted in their names. Federal auditors say that if the payment goes to the physicians, it’s their responsibility to know what codes are being submitted in their names."
The Office of the Inspector General of the U.S. Department of Health and Human Services recently issued compliance program guidance for individual and small group physician practices that includes an expectation of annual compliance training.
Although the OIG has said the guidance is not mandatory, it’s still prudent to make sure your staff is training in proper coding, Swann says.
"Every year, the Inspector General has focused on evaluation and management documentation and coding," Swann says. She quoted Assistant Inspector General Lew Morris as stating that "HCFA has zero tolerance for errors."
A combination of specialty specific training in small groups followed by chart audits with personal feedback is the most effective method for training physicians, Swann says.
"It’s most effective to conduct the training in a small, specific group where all the physicians do the same type of coding. It allows participants to benefit from other people’s questions," Swann says.
At Baylor, new physicians must undergo two hours of evaluation and management coding training, and an hour of training on the rules for supervising residents in a teaching hospital.
As recommended in the OIG’s compliance guidelines, Baylor has annual compliance training for all its staff.
"There’s no need to teach the same thing year after year. We generate our own material through internal review," Swann says. For instance, if chart reviews show a particular problem occurring frequently, the compliance training will include a case-based lesson on that particular code. Swann recommends case-based training with pre-testing and post-testing to evaluate comprehension. Shortly after the training, the auditors should conduct a prospective chart review, or an audit of each physician’s coding before the bill is submitted.
"If we detect errors, we meet with the physician and talk about documentation and the code selected. It’s important for the success of the prospective audit to meet with the physician and discuss what the variances are so we can come to an agreement that the documentation supports the code," she says.
The benefit of a prospect review is that it gives you the opportunity to correct the situation and submit a correct claim the first time. Then you don’t get into a situation where you have to refund the overpayment and re-bill the work.
"It’s more time consuming for a prospective audit but it’s a better way to go. You submit correct bills the first time and increase your cash flow," Swann says.
At Baylor, the staff does a sample of all payers, not just Medicare and Medicaid.
"We thought it would be prudent to include all payers since all expect correct coding," Swann says.
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