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Unintended Discrimination Case

Decent Essays

1. As the new manager for the Revenue Cycle division, I know that each department (scheduling, pre-registration, registration verification, financial counseling, billing, so on) provides an opportunity for error and risk resulting in unpaid claims. What kind of compliance plan is in place to minimize inaccuracies?
a. First, we have established written policies and procedures that is the Standard of Conduct. Employees are expected to follow the standards set forth in the plan as well as applicable laws. It is important to point out that our Corporate Compliance Plan is flexible and readily adaptable to changes in regulatory requirements. Our plan is reviewed annually and modified as necessary. We have a centralized revenue cycle process …show more content…

How are we navigating the compliance minefield that is patient financing?
a. Jake, here are a few common compliance traps we avoid:
i. Unintended discrimination- The Equal Credit Opportunity Act and state laws promote access to credit for all creditworthy applicants regardless of certain factors (race/origin/sex/marital status/age). While screening patients before offering them a payment plan may seem like good business, it may be illegal if not done properly. ii. Not providing adequate disclosures- The Truth in Lending Act Reg Z and other state laws promote the informed use of credit by requiring meaningful disclosure of credit terms. Hospitals/medical groups that offer payment plans with a finance charge or a written agreement to pay in more than 4 installments may be considered creditors who are subject to TILA. Informing patients (at registration, signs/posters) and having them sign agreements is critical. iii. Violating collection regulations- State and local laws restrict when and where a creditor may contact a patient regarding payments, impose written and telephone disclosure requirements, and restrict nature of conversation. We have trained all employees and require on-going education on the laws around this …show more content…

Do the coding compliance department report audit results?
a. Yes- all audit results are reported and distributed with respective departments. Results are reported with coding, clinical, and billing departments to ensure that correct claims are properly put into place.
9. Does the revenue cycle department have adequate resources for carrying out its mission?
a. The department’s budget is audited annually to ensure that the stakeholders are able to perform their duties. Moreover, staff utilization and workflow audits are also conducted to ensure an accurate revenue cycle process.
10. Who is responsible for the chargemaster so that we maybe reimbursed properly?
a. An up-to-date and accurate chargemaster is vital to the organization seeking truthful reimbursement. An incorrect CDM could result in overpayment/underpayment, claim rejections, fines and penalties. Our CDM is not the exclusive responsibility of one individual but rather a committee composed of key facility representatives. The CDM is review periodically and proper maintenance requires expertise in coding, billing, clinical, and health record

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