Compliance Action Plan. Target Date. Responsible Parties. See 1 above. Management. 6 Educate staff, physicians and management on proper use of

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Norman Wright
5 years ago
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1 Compliance General Compliance Training 1 General compliance training for all Department employees and Management on recognizing and reporting potential compliance issues. 2 Educate Department Managers regarding compliance program. 3 Add compliance column to Newsletter. 4 Publish and educate all employees on Code of Conduct. Training session to be done after hours non-exempt employees will be paid to attend. CEO to open session CO to conduct training. Every other month. Compliance Program Review Coding references 5 Job-specific compliance training for all Department employees and Management. 6 Educate staff, physicians and management on proper use of ABNs. 7 Arrange for appropriate physician training on E/M coding by an On hold until audits are completed. external resource. 8 Train physicians on compliance. On hold until audits are completed. 9 Follow up on all training to make sure it takes root. On hold until audits are completed. 10 Communicate to Department employees that the issue is being addressed, and validate their concerns. 11 Educate employees on how to appropriately report compliance concerns. 12 Create customized Compliance Programs for each entity. Present recommendations to Compliance Committee. 13 Retrieve all existing coding references at the Department, check them for accuracy, and revise them Request information from Department managers. as necessary. Page 1 of 5

2 14 Develop inventory of required policies and procedures. 15 Write policies and procedures noted in 14 above. Compliance Project Government audit 1 Continue to communicate with investigators representative and work toward resolution. 2 Monitor mail for communication from FI on any further action on this issue. Audit charges for visits 3 Gather data to validate whether there is an issue. 4 Create separate Action Plan and take all necessary remedial actions.. coding and billing 5 Gather data to determine whether there is an issue. 6 Create separate Action Plan and take all necessary remedial actions if there is an issue. Department's charges 7 Gather a random sample of charges and validate whether there is an issue. 8 Create separate Action Plan and take all necessary remedial actions if there is an issue. Credit Balances 9 Review credit balance reports for all payors. Assuming there is no issue, document in Memo to file. HIPAA Assessment 10 Conduct a "walk through" of Department and perform a HIPAA assessment. Make any necessary changes and communicate to staff. Page 2 of 5

3 OSHA Review Review of the billings 11 Conduct a "walk through" of Department with custodial and maintenance staff. Make any necessary changes and communicate to staff. 12 Evaluate need for discovery sample audit. 13 Document recommendations. Based on the review of records done related to, no further action required. Management Compliance program structure 1 Discuss program structure and management and enact any appropriate changes. Billing staff personnel issues 2 Evaluate and educate as appropriate. Work environment. 3 Evaluate and develop action plan to resolve any identified issues. Department staff training 4 Assess substantive knowledge of staff and obtain appropriate training/education for them. Improve communication and collaboration 5 Work with Department to set up faceto-face communication between staff, with a set agenda to go over recurring issues. responsibilities 6 Create a new job description for position. Delineation of roles between 7 Communicate with management and staff revise management structure and accountabilities. Senior Management 8 Clearly define job responsibilities. Hold for completion of overall Compliance Program plan. 9 Consider revising the management structure to ensure better communication, collaboration, and accountability. Operations Page 3 of 5

4 Commercial payor issues 1 Obtain copies of all payor audits. Contract Review 2 Inventory of related contracts. 3 Work to get appropriate contracts in place. Audit follow-up 4 Communicate with Department about proper approach and response to reports and audits. Monthly Error Reporting 5 Establish procedures for the documented accountability and resolution of reported errors. Billing Policies and Procedures 6 Develop inventory of appropriate policies and procedures. 7 Write policies and procedures, and communicate them to the appropriate personnel. 8 Audit consultant report for completion. Forms approval process 9 Review policies and procedures on new forms and refine as necessary. See 1 above under Compliance General; Compliance Training. Physician coding practices 10 Develop uniform practices, obtain physician buy-in, and train physicians and Department staff on the new practices. Human Resources Staff Issues 1 Follow-up on issues raised by staff to Human Resources. Exit Interview Procedures 1 Communicate with Human Resources personnel and develop procedure for engaging in more exit interviews and for capturing potential compliance issues in the process. 1a Revised Exit Interview worksheet. Page 4 of 5

5 Physician awareness 1 Communicate with physicians about appropriate next steps and seek to obtain their buy- in. E/M Compliance Project Physician audits 1 Completion of statistically valid audits of physician records. 2 Project target date for completion of physician audits. 3 Review of initial audit results Response and repayment 1 Conduct further documentation, coding, and billing audits and take all necessary actions, including repayment, to remedy all instances of non-compliance and to prevent future compliance lapses. Build into the Compliance Program. Letter to Carrier 1 Notify Carrier of compliance issue and status of work being done. Physician Communication 1 Project Update. Monitoring of Action Plan 1 Meetings a necessary to monitor progress of implentation of action plan. Page 5 of 5

Oklahoma Health Care Authority

Oklahoma Health Care Authority Recovery Audit Contract Provider Outreach & Education Presentation October 22, 2013 1 Agenda Introductions HMS Overview Medicaid RAC Review Process Provider Outreach & Education