Can You Do It Yourself?
The way to stay out of hot water is to learn the regulations and
assign an employee the task of keeping the practice in compliance. In a
small office, it will likely take about 15 hours per month to research
and develop a protocol, maintain the protocol and train employees, said
Michael Manere, vice president of sales at Total Compliance Solutions in
Wellesley. However, he compares compliance to doing your own taxes. You
can do it yourself, but do you really want to? “You don’t
have your employees do your taxes; what makes you think they’re
going to [create the right] HIPAA program?” Manere said. The costs
to hire a third party to provide a compliance program vary by the size
of the practice and services provided.
While Manere’s operation charges $1,400 for the research and
development of a site-specific program, Vincent DiCianni’s
Affiliated Monitors in Boston charges roughly $6,000 for a package that
includes conducting an audit for a small practice, drafting a compliance
manual and training the staff. Lyn Henderson, vice president of medical
staff and regulatory affairs at the Needham campus of Beth Israel
Deaconess Hospital and a private compliance consultant, said she might
charge $24,000 for a complete compliance package for a 10-doctor group,
which includes her ongoing consultation. Of course, for these prices,
different services are included.
While they are obviously biased, third-party companies note that
these charges pale in comparison to the fines an insurer or Medicare
might levy on a practice that’s noncompliant. “It’s
better to be proactive,” DiCianni said. “It’s better
to recognize that maybe it’s time to have somebody else come in
and look at what you’re doing. We all have blinders on when
we’re dealing with ourselves.” If bringing in a third party
won’t work, he suggests doctors attend coding seminars to stay in
touch with regular practices. It’s not uncommon for a practice to
develop its own shorthand that isn’t the same as standard
coding.
While it’s okay to do that, it’s also important to
document what your own codes mean, keep your key with the records and
distribute it to your entire staff, he said. Recordkeeping classes also
teach an approach to charting, and then a physician’s practice can
conduct a random audit to evaluate proper implementation, DiCianni
noted. Probably the most important aspect of regulatory compliance is
ensuring that members of your staff are adequately trained. Manere said
he often walks into offices where office staff members have been
following the various regulations to the best of their ability, but the
physicians have never written a policy and never officially trained
their employees on compliance.
Compliance doesn’t happen overnight, and physicians don’t
have to tackle everything at once, said Anne Huben-Kearney, a clinical
manager in the risk management department at ProMutual Group in Boston.
She suggests starting with setting up systems to bring high-risk areas
such as Medicare, Medicaid and insurance billing into compliance first,
and then moving on to other areas.
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