Corporate Compliance

Tip: Policy and procedure inclusions

Compliance Monitor, May 19, 2010

A hospital’s written policies and procedures should prove that it has a strong compliance program and a willingness to comply with current regulations. Communication is key. Policies should allow billing and reimbursement staff to communicate with clinical staff members to address and correct any issues that may arise.

Include the following directives in your policies and procedures per the Office of Inspector General’s (OIG) guidance:

  • Accurately document all services prior to billing.
  • Submit claims with appropriate documentation and maintain that documentation so it is available for audit and review.
  • Report only the diagnoses and procedures that are contained in the medical records and other documentation. Make the documentation requirements for accurate code assignment available to the coding staff.
  • Do not provide any financial incentive to billing department coders and billing consultants to upcode claims.

This week’s tip was adapted from The Compliance Officer’s Handbook. For more information about the book or to order your copy, visit the HCMarketplace.

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