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* Changing patient status on rejected claims
* Should we hold exit interviews for fired employees?
* Pay-per-view article: Consider using a "layered" notice of privacy practices

Compliance Monitor, May 4, 2003

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Q: How should our hospital handle claims that we originally bill as outpatient, but are returned with the procedures ruled as inpatient only? When this happens, we don't receive any reimbursement. If we obtain proper documentation from the physician to convert the patient's status to inpatient, may we re-bill the Centers for Medicare & Medicaid Services (CMS) using an inpatient claim? We have a process in place that catches these on the front end, but what should we do with all of the rejected claims?

A:I suggest a process review to avoid this problem. It is important to know internally if services are rendered as inpatient or outpatient, and then billed accordingly. From my experience on the payer side, I would be particularly interested in claim appeals that change the place of service. That could be enough to trigger an audit.

If the place of service was in fact inpatient and, through the billing process, it was reported incorrectly, try gathering all pertinent claims, attach clinical chart documentation supporting the correct place of service, and then submit this to the payer with a letter explaining your error. Include any documentation that details how your facility corrected its billing mistakes.

I would also purchase software or review the 2003 National Physician Fee Schedule Relative Value File, Addendum E. It documents the codes affected by the inpatient-only rule. Then, educate your medical and billing staff.

This question was answered by Barbara Aubry, RN, CCM, CPC, DABQAURP, a clinical business analyst with Info-X-Inc.

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Pay-Per-View article: Consider using a 'layered' notice of privacy practices

The privacy rule's requirement to provide patients with a notice of privacy practices is meant to educate patients on how their health information may be used. The document's purpose is to stress the importance of protecting the confidentiality of that information, not to load patients down with more paperwork that they leave behind in the physician's office, says Jerry Griffin, EdD, senior vice president and compliance officer at Health Care Compliance & Practices Co., in Tulsa, OK...

Go to "Consider using a 'layered' notice of privacy practices" for the rest of this article. The cost is $10. Subscribers to the online version of Briefings on HIPAA have free access to this article. Subscribers to the print edition can find it in their May issues.

A $30 steal!

You can read this article-and much more-in the May issue of Briefings on HIPAA. Your cost: Six stories for only $30! You'll learn how to take a performance improvement approach to HIPAA compliance, and how the Casa Grande Regional Medical Center used levels of access to comply with minimum necessary. Choose between a PDF or HTML version for just $30. Online subscribers have free access to this issue. Print newsletter subscribers can find it in their mailboxes.

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Should we hold exit interviews for fired employees?

Q: Our organization performs exit interviews for employees who voluntarily leave. In that exit interview, we ask the employee whether any compliance-related issues arose during employment. Should we also conduct exit interviews for employees we terminate?

A: Congratulations on conducting exit interviews and on asking compliance-related questions. This is an overlooked compliance tool. I definitely recommend extending your exit interviews to terminated employees. While exit interviews with employees leaving under less-than-cordial circumstances are difficult, they can provide excellent feedback on both human relations and compliance matters. Occasionally, terminated employees become whistleblowers. If there is a well-documented exit interview in which they denied the existence of any human resources or compliance issues, that documentation serves as excellent evidence to defend against a whistleblower allegation. If a face-to-face exit interview is not feasible, consider mailing an exit interview form to the terminated employee after a brief cooling down period. Ask them to reply by mail or telephone.

This question was answered by Charles Colitre, president of Med-Management Group, Inc., a consulting firm in Akron, OH that assists physician practices and hospital systems to develop and implement compliance programs. Colitre is a retired FBI Supervisory Agent who supervised health care fraud investigations.

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