Corporate Compliance

*Staying on top of credentialing due dates
*Looking for answers to cataract surgery denials
*Sidestepping the five most common FDA compliance pitfalls

Compliance Monitor, September 26, 2003

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September 26, 2003
Vol. 6, No. 77

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"Strategies for Health Care Compliance," a 12-page monthly newsletter, helps you thrive in the ever-changing compliance environment by providing easy-to-understand compliance advice and analysis of the latest regulations. Each month, this newsletter offers how-to tips, features about your peers, policies and procedures, and tools for improving the efficiency and effectiveness of your corporate compliance programs. To learn more, click here or call 800/650-6787.

On Complianceinfo.com

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

Sample audit programs. (For subscribers to Health Care Auditing Strategies only)

The OIG Work Plan for Fiscal Year 2003

Ask the Expert

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 Kate Alvarez at kalvarez@hcpro.com. We hope you enjoy this service and we welcome your feedback.

This week's questions

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Quick survey
Questions and Answers

Staying on top of credentialing due dates

Q: If a provider is due to be credentialed, for example in January, but does not actually do it until May, based on a 24-month recredentialing cycle, should the renewal be completed two years from January or two years from May? Will the earlier recredentialing be acceptable to the National Committee for Quality Assurance?

A: Technically, a managed care plan would terminate a provider who was not recredentialed on or before their due date. The provider would be out of compliance according to accreditation standards and the department of insurance level used by most states.

The provider's next recredentialing date should fall within the two- or three-year requirement based on the May 2003 credentialing date. Keep in mind that the Utilization Review Accreditation Commission (URAC) and a majority of state insurance departments are increasing the re-credentialing time frame to a three-year cycle.

If the provider had completed the process in January 2003, their renewal date would continue to show a due date in January, but the four-month lapse between the due date and actual date of credentialing, shifts the next recredentialing date to May. It's good practice to send notification of the recredentialing process out to providers six months before the due date in order to guard against possible termination issues due to non-compliance.

Source: The North Carolina Department of Insurance Administrative Codes 20.0401, as well as URAC guidelines for credentialing.

This question was answered by Mary Anita Kahler, RHIT, Manager Professional Network Services for MedCost Inc. Kahler is an experienced office administrator, specializing in credentialing and managed care contracting.

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Tell us about your financial policies.

Click here to take our quick survey on your financial policies and procedures.

The long awaited EMTALA rule is finally here!

EMTALA governs the way hospitals manage patients coming into the emergency department, and how and when those patients can be transferred. The government has finally released the final EMTALA rule-and it takes effect November 10. Join us for a very important 90-minute audioconference, "EMTALA final rule: New strategies for compliance" on September 30 beginning at 1 p.m. Eastern and learn everything you need to know to get ready. Our speakers will dedicate half the program time to answering your questions.

For information or to register, CLICK HERE, or call our customer service department at 800-650-6787. Be sure to mention Source Code EZ23288B.

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JOIN THE COMPLIANCE MONITOR TEAM.

Are you a compliance expert? We're looking for compliance experts in coding, billing, documentation, HIPAA, EMTALA, Stark, laboratories, and many other areas of compliance. If you are interested in answering questions from your peers, please e-mail Compliance Monitor editor Kate Alvarez.

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Pay-Per-View article: Sidestepping the five most common FDA compliance pitfalls

The FDA has numerous regulations that govern clinical research-but they tend to be the same rules that trip up research sites and result in compliance violations. From inadequate informed consents to protocol deviations to problems with drug or medical device accountability, the FDA is repeatedly citing facilities for the same issues-which can result in warning letters, debarments, or even having a trial shut down.

Matthew Purner, a senior associate with Pricewaterhouse Coopers LLP in Los Angeles, and Robert Nicholas, a partner with the law firm of McDermott Will & Emery in Washington, DC, say the most common violations of FDA regulations are too often caused by poor record-keeping and lack of training.

They identify the most common causes for FDA sanctions below and outline some suggestions that can help your organization avoid problems.

To find out more about the most common FDA compliance pitfalls, order the pay-per-view article "Sidestepping the five most common FDA compliance pitfalls." The cost is $10. Subscribers to the online version of Clinical Trials Compliance have free access to this article. Subscribers to the print edition can find it in their September issues.

A $30 steal.
You can read this article and much more in the September issue of Clinical Trials Compliance. Your cost: Five stories for only $30. You'll also learn ten steps to creating a solid auditing program to monitor clinical trials, why standard of care issues were the topic of fall meeting, how an expedited IRB review may save time, and about two new clinical trials lawsuits filed by Milstein.

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FIVE RESOURCES to help you build an effective and sustainable HIPAA compliance program

Give your HIPAA security and privacy compliance program a boost with the "HIPAA Security and Privacy Reminder Toolkit." Take a look at what's inside:

  • The video training tool, "Protecting Patient Privacy: Your Role in Patient Rights under HIPAA"
  • The CD-ROM Q&A resource, "H-Mail, Second Edition: HIPAA Privacy and Security Training Reminders for the Healthcare Staff"
  • The CD-ROM, "HIPAA Compliance Cartoons," for use in your staff education program
  • "HIPAA Security and Privacy Posters" to reach large numbers of staff repeatedly
  • "HIPAA Security Reminder Screensaver" to promote HIPAA awareness and protect PHI

    To order, or learn more, Click Here. Or, call 800/650-6787 and mention source code EB23246G.

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    Looking for answers to cataract surgery denials

    Q: Medicare repeatedly denies our claims for cataract surgeries based on a lack of medical necessity. We have reviewed our local medical review policy and are not able to identify any problems with our documentation. The fiscal intermediary has directed us to appeal the denials, but they have not explained why the rejections are happening in the first place. While the appeals process may help with existing claims, it does not allow us to identify and eliminate potentially problematic documentation in new claims, thus continuing the denials. How can we get the answers we need to clean up our problem areas and stop the denials?

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

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    Quick survey: Does your organization train employees on Medicaid compliance issues?

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

    Here are the answers to the last survey:

    When will your organization begin auditing its HIPAA compliance program?

    • Within the next six months: 68%
    • In 7 to 12 months: 17%
    • In 12+ months: 9%
    • We do not plan to audit: 6%

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    Network with your audit colleagues

    "Audit Talk" is a new, moderated chat forum that members can use to post messages or questions for their peers 24-hours-a-day. "Audit Talk" offers a free forum to network, share ideas, and solve problems for those in the audit industry. Getting involved is easy. To subscribe, just send your request to this e-mail: owner-audit_talk@hcpro.com.

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    Share the news

    You've been benefiting from our informative e-mail newsletter, so why not pass on this resource to your peers? Sign up a colleague and get $20 off your next purchase on HCPro's Healthcare Marketplace!

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    Send your comments and questions about Compliance Monitor Q&A to:

    Kate Alvarez
    Editorial Assistant
    kalvarez@hcpro.com



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