As is the case for healthcare professionals across the care spectrum, compliance resources for physical therapists are constantly evolving—forcing you, the rehab and remediation specialist, to wear many hats. Not only are you treating patient impairment and injury on a day-to-day basis, but you’re also responsible for ensuring that you and your practice meet a slew of ever-changing regulatory requirements.
Man—and you thought finding treatment slots for your growing Rolodex of patients was a challenge. Don’t worry—you’re certainly not alone, as a number of physical therapy professionals are in the same boat, wondering which resources they need and where they should turn to find the answers to all of their burning compliance questions. So, who you gonna call to make sure your PT practice is meeting various HIPAA, Medicare, and Office of the Inspector General (OIG) standards? There’s plenty to consider before picking up the phone to hire any sort of outside compliance professional, and we’re here to help.
Contact your MAC with questions about billing and claims.
Medicare’s policies—around coverage, payment, coding, documentation, and billing requirements—are anything but clear (how’s that for the understatement of the year?). CMS offers plenty of resources to help providers navigate the ins and outs of Medicare regulations—as does WebPT—and we recommend educating yourself on those regulations as much as possible. That way, you have the best possible shot of adhering to the rules—and avoiding throwing up any compliance red flags.
Then again, not everything related to Medicare billing and payment is under your control—and that’s where Medicare Administrative Contractors (MACs) enter in the equation. MACs handle a plethora of compliance-related tasks, including probe audits, or prepayment review of claims that target “either particular services or particular specialties.” Essentially, if you meet certain criteria for a probe, auditors will pull a sample of your submitted claims for review prior to payment. From there, MACs will solicit requests for additional billing information, which you must supply to receive proper reimbursement for claims.
So, when would be an opportune time to contact a MAC? Ideally, you’d seek the advice of your MAC before discovering that you’ve been pegged for an audit. Remember, your MAC is your primary point of contact for ensuring accuracy in the receipt, processing, and payment of your Medicare fee-for-service (FFS) claims. So, if you’re ever unsure of whether you are adhering to the Medicare policies that govern these processes—or if you have any related questions—then you’d be wise to get in touch with the MAC serving your region. (Not sure who that is? Visit this CMS page to find out.)
Turn to industry attorneys for customized compliance solutions.
Let’s face it: compliance may not be your forte. Fortunately, you can turn to experts like healthcare attorneys—who can create solutions specifically tailored to the needs of your rehab therapy practice—for help. These specialized lawyers can provide compliance advice, help you draft contracts, and aid in the creation of company policies on compliance. Plus, if your practice were to incur any compliance violations, a healthcare attorney could assist with any resulting investigation or litigation. Now, I’m going to be honest with you: legal services—especially super-niche legal services—can be pricey. But, the cost may be worth the long-term peace of mind, as a healthcare attorney can help you uncover any potential compliance risks, as well as prioritize which issues need to be resolved pronto.
To that end, if you take a proactive approach to getting your legal affairs in order—by enlisting a legal professional to craft company contracts and compliance plans that account for future trends and developments—then you may be able to stave off any potential legal complications (and avoid keeping your attorney on retainer). Sure, the upfront investment might be hard to stomach, but it pales in comparison to the potential cost of a compliance slip-up. Plus, once your attorney does all the heavy lifting, it’ll make it much easier for you—or another designated employee—to confidently handle future compliance-related tasks.
Connect with consultants to cultivate a top-notch compliance program.
One of the keys to a successful compliance program is making it a truly living and breathing part of your organization. Your compliance plan is more than a record of ideas and considerations for the future; it should be a palpitating heartbeat constantly pumping life into everything your organization does and stands for. These plans include evaluation of risk areas in:
- hiring practices;
- billing compliance;
- medical records releases and informed consent;
- confidentiality and patient rights; and
- employee safety, rights, and obligations.
Now, you’re probably not an expert in all these areas—which is exactly why you may want to consider enlisting a savvy healthcare consultant to help you develop a compliance program that covers each of these facets. So, whereas a healthcare attorney draws up contracts and policies on already-established compliance protocols, a knowledgeable consultant should be able to strategize and create a plan specific to your practice.
In the market for a compliance expert? You’ll likely find that there are plenty of qualified, eager candidates from which to choose—and their price points may not all be the same. But rather than picking a candidate all willy-nilly, you should make sure your prospective consultant has the credentials, background, referrals, and cost range to satisfy your clinic’s needs. Your consultant’s fees should definitely be on your mind, but it shouldn’t be the be-all and end-all of your negotiations. As PT Compliance Group explains: “Compliance should be your number 1 investment in taking your practice from good to great. Think of compliance as an investment in your business, not a cost.”
Take heed on these final thoughts.
There you have it: these are some of the resources at your disposal for developing a strategy around corporate compliance. There is no one-size-fits-all approach, so make sure to do your homework before deciding which avenue works best for you. Finally, don’t be afraid of no ghosts—err, I mean, don’t be hesitant about contacting fellow rehab therapy colleagues, or joining professional associations or online groups to get some advice on the matter.
What remaining questions do you have about developing a compliance strategy for your practice? Already experienced success in this area? What tips or considerations would you give to rehab therapy professionals looking to hire someone for the first time?