Corporate Compliance

* How large should our audit sample be?
* How can we convince our physician to complete the superbill?
* Don't take transactions testing lightly

Compliance Monitor, June 22, 2003

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Vol. 6, No. 47


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On Complianceinfo.com

Sample compliance policies and procedures. (For subscribers to Strategies for Health Care Compliance only)

The OIG Work Plan for Fiscal Year 2003

Ask the Expert

Tip of the Week

Compliance Hot Topics: Billing and Coding, EMTALA, Stark, HIPAA

Question of the Week

Welcome to Compliance Monitor Q&A!

Our mission is to answer your difficult compliance questions-and your simple ones, too. To submit a question, send it to Compliance Monitor Q & A editor Laura Motta at lmotta@hcpro.com. We hope you enjoy this service and we welcome your feedback.


This week's questions

Pay-per-view article
Quick survey
Questions and Answers

How large should our audit sample be?

Q:We are a laboratory system with five hospital labs and one outreach lab. What is an appropriate number or percentage of bills to audit for Medicare compliance?

A: In performing a compliance-related internal audit, the size and type of medical records you use depend on what items your facility wants to audit. The internal audit sample should be large enough to offer valid results, but not so large that the audit is time consuming. There is no set formula on how many medical records you should review. But the Office of Inspector General (OIG), in its Compliance Program Guidance suggests using the following for a coding audit: "a randomly selected number of medical records ... to ensure that the coding was performed accurately."

Here are some basic steps:

  1. Establish the universe (timeframe) from which to draw your charts. This will depend on the overall volume of work your facilities perform. Adjust the timeframe accordingly to maintain a workable volume. For example, you might want to see how many claims were performed for a quarter of a selected year. And depending on the volume, you might want to review one month of claims from that quarter.
  2. Pull a good representative universe to include all payer types, including Medicare, Medicaid, and private payers.
  3. Then, try pulling every tenth claim from the selected universe for review (or a 10% review). If the volume of claims is too large, scale it back.
  4. You could then isolate the review to specific areas of concern, or pull only certain problematic types of claims, but do this after you've conducted your general audit.

The last issue is frequency. Depending on the universe you review and its volume, you might want to perform internal audits monthly, twice a year, or annually. This is a question that will depend totally on your office volumes and needs.

Hold training if necessary after each audit. Repeat the audit in a reasonable timeframe to test whether your training was effective, and to correct any previously isolated billing, coding, or other problems.

This question was answered by Rick Oliver, JD, CHCO, CPC, MT (ASCP), director of compliance at AmeriPath, Inc.

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Is your Chargemaster up-to-date?

If not, you could be losing thousands of dollars and jeopardizing your compliance standing with the government. Don't take chances! Plan to spend 90 minutes on June 17 for an important audioconference, "Essential Chargemaster Maintenance: Best Practices to Ensure Positive Financial Outcomes and Compliance." It's a small investment compared to what you could be losing.

To learn more or to register, CLICK HERE or call our customer service department at 800/650-6787. Be sure to mention source code EZ0175A.



Pay-Per-View article: Don't take transactions testing lightly

Contrary to what some facilities believe, the next major HIPAA compliance date is not the security rule's April 21, 2005, date. It's this October 16.

The Administrative Simplification Compliance Act gives covered entities that submitted compliance plans to the Department of Health and Human Services until then to comply with HIPAA's transactions and code sets rule. The agency expected you to begin testing by April 16. Now you have four months left to comply with the rule...

Go to "Don't take transactions testing lightly" 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 June issues.

A $30 steal!

You can read this article-and much more-in the June issue of Briefings on HIPAA. Your cost: Five stories for only $30! You'll learn how to convey five key points about HIPAA privacy to your staff. You'll also learn when the privacy rule permits disclosures to public health authorities. 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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Avoid FCA prosecution for poor quality of care

Join HCPro for the 90-minute live audioconference, "Quality of Care Meets Corporate Compliance: How to Avoid Prosecution Under the False Claims Act" and learn how to enhance your facility's quality improvement process to comply with all government billing and patient safety regulations.

This program will be presented on Thursday, June 19th, 2003, at 1:00-2:30pm (Eastern). To register or learn more, click here. Or, call 800/650-6787 and mention source code EZ0873A.



How can we convince our physician to complete the superbill?


Q: Our physician is throwing a fit! He has not been signing and dating the superbill, nor has he been writing or circling the diagnosis on the superbill. The nurse staff and the clerical staff have been completing the superbill without the signature. I was informed at a workshop that the superbill is a legal document and he must sign and date it, and put the diagnosis on it because of compliance and legal concerns. Our physician wants book, chapter, and verse to prove that this is a legal issue and not some proficiency and efficiency rhetoric from me.

A: To read the answer to this question, Click here.

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Quick Survey

Are you concerned that the new outliers rule will have a negative impact on your organization's reimbursement?

To submit your answer, go to the Question of the Week at Complianceinfo.com.

Here are the answers to the last survey:

How big a challenge is it to effectively and efficiently respond to patient complaints at your facility?

  • Major challenge: 15%
  • Somewhat of a challenge: 41%
  • Minor challenge: 44%

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Editorial Assistant
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