A movie called Fools Rush In came out in 1997 (worth noting this was over 20 years ago).
Three years later in October 2000 the federal Office of the Inspector General (OIG) established written compliance program guidelines for Individual and Small Group Physician Practices.
The OIG’s compliance guidelines outline seven elements as voluntary measures individual and small group physician practice (and dental practices) should implement in effort to demonstrate their commitment to prevent criminal fraud and a high level of corporate integrity.
The seven elements include:
1. Implementing written policies, procedures and standards of conduct.
2. Designating a compliance officer and compliance committee.
3. Conducting effective training and education.
4. Developing effective lines of communication.
5. Conducting internal monitoring and auditing.
6. Enforcing standards through well-publicized disciplinary guidelines.
7. Responding promptly to detected offenses and undertaking corrective action.
Perhaps the most crucial of these elements is #5.
Internal monitoring and auditing is essentially going back to check your work. In this case, the work you need to check is your coding, clinical documentation and billing.
The best time to check your work is before you send your bill to get paid/reimbursed for services rendered.
The next best time to check your work is after you submitted for payment.
Many dentists and dental organizations has some form of pre-bill audit system in place to minimize mistakes on the front end. Whether you do this or not, it is imperative that you begin doing so at once.
Your process should be outlined in a written policy and procedure and be supported by some sort of audit record/ paper trail.
Not only should you have a pre-bill audit process, but you should have a post-bill (retrospective) audit process that is more in depth and qualitative. This process should also be a written policy/procedure. You should also create and maintain audit records.
Retention of audit records is important because by performing internal audits, you are creating evidence to demonstrate your best efforts to identify and prevent criminal fraud and minimize mistakes. These mistakes can result in fraud-like consequences such as payment holds, pre-payment review, exclusion from provider networks, third-party/government audits and investigations, license sanctions, loss of license, even criminal prosecution and incarceration.
Audit records are evidence your healthcare attorney can leverage to minimize or negate these consequences.
Your audit processes and resulting records – AND your response to detected concerns can REALLY make or break you if someone finds errors in your recordkeeping, causing you to defend yourself against a fraud allegation, but don’t take my word for it.
As a former law enforcement officer, I investigated dentists for a living. I know how government agents think when they work fraud cases.
I am not a dentist.
I am not an attorney.
I have been in the trenches supporting dentists and their attorneys for over eight years.
I have ‘been there’ and ‘done that’ with dentists who have been audited and/or investigated for civil and criminal fraud.
I feel like the Farmers Insurance commercials really outline my professional life in that “I know a thing or two because I have seen a thing or two”.
Don’t have time to do your own record auditing? Outsource it.
My team and I have been auditing dental records for dentists and dental organizations across the country since 2012.
The reality is that you WILL be audited at some point. Fail an audit and you will be audited often thereafter (after recoupments, payment holds or worse).
Take it from me, you need to audit your records.
If you won’t do it (or don’t want to), I will.
When we audit, you get feedback you can use to make corrections without the consequences that insurance carriers and government agencies give you.
Our fees are a fixed expense (investment) for you in effort to minimize negative consequences next time you are audited by an insurance carrier or the government.
If you are already in trouble have your attorney call me.
Let’s work together to figure out your situation!
In any event, I am glad you are no fool.
I am glad you did not rush into implementing the OIG’s compliance guidelines.
It has been over 20 years since the guidelines were published.
It is about time you get in the game before it costs you BIG $$.
*** Duane Tinker ***
Chief Compliance Coach & Consultant
Dental Compliance Specialists
CONNECT WITH DUANE
Dental Compliance Specialists helps make dental offices safer for patients, dentists and their employees. We help our clients develop and maintain their compliance programs including OSHA/Infection Control, HIPAA, DEA regulations and prescribing practices, Radiation Safety, OIG/Medicaid Compliance, Record Auditing, and more by providing actionable systems, easy-to-use tools, robust training, and accountability. Most of our clients have never been in trouble and want to keep it that way. Sometimes, though, dentists call when they are in trouble. In either case, we are there to make a meaningful difference. If you need help call us at 817-755-0035.
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