Making Your Agency Compliance Strong for 2015 and Beyond

There is a seemingly constant stream of grabbing headlines revealing yet another behavioral health or human services agency being penalized under payer take-backs or even accused of fraud, but for many providers these horror stories have not been enough to drive them towards compliance action.

In this post, we’ll take a closer look at compliance for behavioral health and human services providers, and reveal the best practices to guarantee that your agency is compliance strong for 2015 and beyond.

The Rise of the Take-Back

Providers not yet prioritizing compliance should tread carefully, especially considering the prevalence of payment reform causing payers to ramp up their compliance efforts in the form of persistent audits. This combined with the advent of incentive programs, means that payers are looking to minimize costs by enforcing take-backs whenever possible.

These take-backs or the mandatory repayment of overpaid funds continue to hit the healthcare industry hard, but for behavioral health and human services providers, take-backs can mean the difference between agency stability and a funding crisis.

The impact of take-backs is further amplified by existing funding issues which contributing to the extreme likelihood that overpaid funds have already been spent. This leads many providers to resort to desperate measures including layoffs in order to secure funds for repayment.

7 Steps to Guarantee Compliance Excellence

Providers can move closer to effective compliance measures and audit safeguards by following these key steps:

Adopting a Leading EHR
EHRs are one of the most effective compliance tools in a provider’s toolkit. The most effective EHRs make clinical documentation a part of the clinician’s workflow and require the completion of proper documentation for every service provided before a claim can be submitted. This level of checks and balances, makes documentation a natural part of the clinician’s day and integral to the billing process.
Assigning a Point Person
For behavioral health and human services agencies of any size, compliance starts with a point person, the Compliance Officer. This person manages and oversees all agency compliance efforts.

Avoid: the Compliance Officer/Jack-of-All-Trades. Unfortunately, many agencies that already have Compliance Officers encourage them to priorities other responsibilities unrelated to compliance. These responsibilities usually take precedent over compliance and all compliance efforts are pushed further and further back. Avoid this common pitfall at all costs.
Building Your Compliance Dream Team
Establish a committee of stakeholders from across the agency to ensure that the unique compliance concerns of each department are represented. Compliance teams create greater accountability, build staff buy-in and result in stronger compliance initiatives.
Getting the Rest of Your Agency On-Board
Start with the message that prioritizing compliance is mandatory and essential to each person’s role. Incorporate this message into regular staff trainings on compliance and highlight how compliance will benefit the work they do on a daily basis. Educate the entire agency on the necessity of compliance, especially all members of the management, clinical and billing teams.

Avoid: Take-backs and repayment will be too abstract for the larger agency and should not be the primary message of your compliance training nor should it be the primary goal of your compliance efforts. Providers often forget that the most profound impact of compliance is not avoiding penalties, but positively impacting quality of care, efficiency and overall cost management.
Creating a Compliance Roadmap
With help from the compliance committee, the Compliance Officer should create a compliance plan featuring the following components:

> Identification of compliance committee members and Compliance Officer
> Clearly defined compliance objectives and standards
> Internal staff training programs
> Enforcement standards for disciplinary action in response to instances of noncompliance
> Standard guidelines to respond to noncompliance and prevent repeat offenses
Monitoring for Signs of Noncompliance
Continuously monitor for signs of noncompliance. High denial rates and incorrect billings are usually a dead give-away. Pay close attention to clinical documentation, which is consistently one of the highest contributors to noncompliance.
Conducting Audits
Perform regular internal audits to prevent noncompliance surprises and address issues in a timely manner after they arise.

The Compliance Power of an Effective EHR

Qualifacts’ certified Complete EHR, CareLogic Enterprise, enforces the necessary checks and balances to simplify the compliance process and safeguard against failed audits.

With CareLogic, providers can rest easy knowing that…

Proper and completed documentation is required for each specific service provided.
Completion of certain document fields is required and signature validation is enforced to reduce “documentation errors.”
Documentation forms can easily be adapted to changing regulations to ensure that providers are not using outdated forms.
Only “clean claims” are sent out.
The billing staff can mark services as “non-billable” if provided in error. Changing a service to “non-billable” no longer triggers a claim, but allows the documentation to remain in the client’s chart.
Providers receive reliable alerts to notify them of unkept appointments and the need for document completion or signature verification.
For convenience, documentation generates directly from the clinician’s schedule. This means that they do not have to recreate the information in multiple places which saves precious time and energy.