* Can we bill for services if a patient complains about them?
* Do we need to send our NPP to patients who can't read it?
* Medical necessity: Tips for auditing your facility's claims denials
Compliance Monitor, July 22, 2003
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Friday, July 18, 2003 Vol. 6, No. 57 SUBSCRIBE to Compliance Monitor Visit Complianceinfo.com
On Complianceinfo.com The OIG Work Plan for Fiscal Year 2003 Compliance Hot Topics: Billing and Coding, EMTALA, Stark, HIPAA |
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 Melissa Osborn at mosborn@hcpro.com.
We hope you enjoy this service and we welcome your feedback.
This week's questions
Quick survey Questions and Answers Can we bill for services if a patient complains about them? Q: If a patient makes a complaint (valid or otherwise) of being injured as a result of medical care, what options do providers have for charging and billing for that care? A: There is no simple answer for handling a patient complaint and handling the patient's charges. Handle the situation on a case-by-case basis, depending on the complexity of the complaint and its legal ramifications. Even if your medical group or hospital does not have a formal process for handling patient complaints, you still must have an administrative mechanism to allow the patient to complain. This is required under Medicare's "Conditions of Participation." Make sure physicians, staff, and patients know how to file complaints, and learn how your organization responds to them (whether you use a telephone call, a form, or through a point person). Again, Medicare requires you to send a formal letter to each patient who complains. To build awareness, include the complaint mechanism in any brochures that you give to patients. The patient who gets tied up in bureaucracy is more likely to file a lawsuit than one who feels their complaint was heard. You can categorize patient complaints of injury as "informational" and "therapeutic." An information complaint is one in which the patient has a question on how to handle the diagnosis or treatment, or how physicians delivered care, informed consent, or bad outcomes from treatment. Examples of this include the following: In these examples, the patient may have been informed of the side effects, but he or she may have misunderstood the physician. Investigate this complaint promptly and share the results with the patient. Therapeutic complaints focus on serious problems. You must investigate these claims immediately. These complaints stem from the following physician or staff errors: Examples of this include giving a patient an overdose of medication or allowing the patient to drive soon after receiving anesthesia, resulting in a traffic accident. In these scenarios, the medical group may not be able to waive or hold charges to the patient because it has already billed the patient's insurance company for the services. However, the group can flag the account or put it on hold until it investigates the case. This should be done within 30 days. Once you investigate the initial patient complaint and make a resolution, decide whether to reinstate or inactivate the patient account. The most important aspect for handling complaints is to ensure that the medical group pays attention to the patient's complaint. Medical groups and independent physicians must put a strong process in place for handling patient complaints of injury, including handling patient charges and bills. This process should pay for itself in reduced legal action. This question was answered by Michael O'Connell, MHA, CMPE, CHE, senior director of the Cleveland Health Network MSO, LLC, in Independence, OH. New ezine: Health Care Auditing Weekly Setting up and maintaining an auditing program is never an easy task, but HCPro now offers a free resource that delivers helpful news and advice each week! Introducing Health Care Auditing Weekly, the new e-mail newsletter designed for healthcare internal auditors and compliance professionals. Click here to sign up for your complimentary subscription. FREE, NO OBLIGATION TRIAL OFFER FOR CLINICAL TRIALS RESOURCE "Clinical Trials Compliance," a 12-page monthly newsletter, was created exclusively to provide you and your staff with how-to strategies that are missing from today's clinical trials government regulations. We've got your back, whether it's HIPAA, Medicare billing, FDA, or OHRP regulations. Each issue will provide you with case studies, lawsuit alerts, how-to HIPAA pointers, advice from the most well-respected experts in the field, and much more. Click here to register for your three FREE print issues of "Clinical Trials Compliance." Or, call 800/650-6787 and mention source code EN21676A.
Pay-Per-View article: Medical necessity: Tips for auditing your facility's claims denials Claim denials for lack of medical necessity can significantly reduce an organization's bottom line. And hospitals already struggling with medical necessity could see even more denials as fiscal intermediaries (FI) issue new requirements for tests and procedures. . . . Go to "Medical necessity: Tips for auditing your facility's claims denials " for the rest of this article. The cost is $10. Subscribers to the online version of Health Care Auditing Strategies have free access to this article. Subscribers to the print edition can find it in their July issues. A $30 steal! You can read this article-and much more-in the July issue of Health Care Auditing Strategies. Your cost: Three stories for only $30! You'll learn tips for auditing your facility's claims denials for medical necessity, and how to interview and evaluate auditors. 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. We have a new tool to improve outpatient documentation! Did you know that four types of encounters account for over 90% of the facility-based outpatient visits? If your facility is busy with emergency department, diagnostic testing, ambulatory surgery, and observation visits, that adds up to plenty of opportunities to miss appropriate reimbursement due to documentation errors. You need the new book, "Guide to Outpatient Clinical Documentation Improvement: The First Step in Revenue Cycle Management" by Ruthann Russo, JD, MPH, RHIT. For more information, CLICK HERE and save 10% when you order on line. You may also call our Customer Service Team at 800-650-6787. Please mention source code EB1068A when you call.
Do we need to send our NPP to patients who can't read it? Q: Do we need to send a notice of privacy practices to nursing home patients who are unable to comprehend or read it? A: To read the answer to this question, click here. Quick survey Would you be interested in learning how other organizations structure their compliance, privacy, and risk management functions, set procedures, train new employees, and handle reporting and budgets? To submit your answer, go to the Question of the Week at Complianceinfo.com. Here are the answers to the last survey: Are you concerned that the new outliers rule will have a negative impact on your organization's reimbursement?
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