Most billing services know and understand the importance of having a well written contract but not all realize that they also should have a compliance plan in place. A compliance plan is for the protection of both the billing service and the provider. Each provider that they bill for should be given a copy of their compliance plan, and the plan should be reviewed on a regular basis.
Improper billing practices can lead to civil or criminal offenses. More and more providers are turning to third party billing services due to the complexity of billing. Some third party billing services also provide coding and other services as well. It is important that the provider is aware of the third party billing services policies and procedures regarding claims submission and coding. It is best that the policies and procedures are outlined in writing to protect both the provider and the billing service.
In 1998 the Office of the Inspector General issued a guideline for compliance plans for third party billing services. The complete guideline can be found at http://oig.hhs.gov/fraud/docs/complianceguidance/thirdparty.pdf . This guideline includes general principles that can apply to any compliance plan as well as guidelines specific to third party billing services. It identifies risk areas specific to third party billing services such as billing for services not documented, unbundling, upcoding, and inappropriate balance billing. There are seventeen specific risk areas identified.
It also suggests seven steps to prepare an effective compliance plan. The suggested steps are:
1. Implement written policies, procedures, and standards of conduct.
2. Designate a Compliance Officer and compliance committee
3. Conduct effective training and education
4. Develop open lines of communication
5. Enforce standards through well-publicized disciplinary guidelines
6. Conduct internal monitoring and auditing
7. Respond promptly to detected offenses and develop corrective action
If you do not currently have a compliance plan you should implement one as soon as possible. The above list of suggestions should help. When your compliance plan is complete make sure you give a copy to each of the providers you bill for.