Corporate Compliance

Checking up on consultants

Compliance Monitor, April 12, 2006

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It's important to protect your facility from bad advice from consultants that can lead to compliance violations and costly settlements. James Kopf, president of Health Care Oversight, a New York City-based consulting firm, and former director of the OIG Criminal Investigations Division suggests taking the following steps to help separate the good consultants from the bad ones:

  • Check references. Ideally, you should obtain three references from three facilities in different areas of the country, says Kopf. Try to find a good mix of facilities (e.g., a large hospital, small hospital, and rural facility). This won't always be possible, but it can give you an idea of the person's work history and track record, says Kopf.

  • Perform a background check. It's not too much to ask consultants to provide your compliance staff with a statement of qualifications that includes the experience they have and the facilities with which they've worked.

    Make sure that their experience and education match up with the job you hire them to do. For example, if you hire a billing consultant, that person should have extensive experience in billing and coding in a hospital setting. Similarly, if you hire a compliance person, look for relevant compliance experience.

  • Listen to your gut. If you work with a consultant and feel uncomfortable with the advice that he or she gives you, follow your instincts.

    Look for red flags (e.g., a consultant who comes in solely to increase your reimbursement). Also be wary of a consultant who tells you to code something at a higher rate than might be justified, tells you that that CMS doesn't check a certain area, or gives you terminology to use to get a claim approved

  • Check it out. If a consultant gives you questionable advice, don't be afraid to ask him or her to point you to the regulations that support his or her contention, says Kopf. An experienced consultant should be able to refer you directly to the information and help you verify the accuracy of his or her statements.

    Be aware that although there are good consultants out there, there are also bad apples. Taking the time to check them out can save you a lot of headaches and potentially millions of dollars.

    This tip is an excerpt from Strategies for Health Care Compliance.

    Editor's note: If you have a tip that you would like to share with your compliance peers, please send it to Compliance Monitor Editor Kelly Bilodeau and we'll publish it in a future issue of Compliance Monitor.



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