Compliance: Curb Upcoding Mistakes Or Risk OIG Scrutiny
Practice size does not matter when dealing with compliance — even solo practitioners have to stay on the straight and narrow.
Even small dermatology practices have to stay compliant with government regulations — and although this sounds like a simple fact, it’s one that many Part B providers may overlook.
Ensuring physician practice compliance can be a complex path, and many practices think of it is something that large hospitals should focus on — after all, those are the entities that get all of the media exposure when they violate compliance rules. But every practice is responsible for compliance, no matter how big or small.
Doctors Take Note
In some cases, small practices think compliance rules don’t affect them — but also don’t realize they’re at risk of being noncompliant.
Example: “I met with a solo practitioner a few years ago who hired me as a consultant,” says Laura E. Hill, CPC, CPC-I, an Arizona- based compliance consultant.
“It was my sad duty to let him know that his office manager,who submitted all of his claims, was upcoding all of his office visits as she entered them into the computer so that she could pay his quarterly malpractice-insurance premiums,” Hill says. “She had been working for him for 10 years and was a loyal and trustworthy employee.”
The fault was the physician’s, because he never took the time to review the monthly reports that the office manager gave to him, Hill says. He also never looked closely at his deposits into his corporate checking account, where there was an obvious trend toward increased deposits every third month.
Pay attention to your advisors: In the example above, the physician’s accountant had pointed the problem out to him, “but he accepted his office manager’s explanation that insurance…