A False Sense of Security
There is a tendency for EMS administrators to focus on the clinical and operational requirements for their services (for good reason!) at the expense of focusing on and understanding compliant documentation for billing. Many services outsource their billing to third party billing companies because billing for ambulance services is complicated and confusing. In doing this, ambulance services develop a false sense of security and begin to operate under the assumption that the responsibility for compliant billing is off their plate.
This is not the case! Ambulance services contracted with Medicare and most other payers maintain the responsibility to submit clean and valid claims for their services. Contracting with third party billing companies does not outsource this responsibility. Additionally, most contracts with a billing company will include a provision requiring the ambulance service to submit proper documentation to the billing company to bill with. Consider this scenario: A government auditor arrives at your service today and asks what your service has in place for compliant billing. If your first thought is to direct them to your billing company, you probably are lacking a proper compliance program, which would be a major red flag to the auditor. When it comes down to it, only you are responsible for your service’s compliance.
Compliance Starts Internally
The OIG has created a compliance program guidance for ambulance suppliers which we highly recommend your service review. Some examples of the processes your service should have in place include the following:
Auditing: The OIG recommends conducting regular monitoring activities to ensure that your claims are supported by compliant documentation. Many services are surprised to learn that because Medicare pays claims on an honor system, there is no review of documentation prior to payment. Because of this, many problems with documentation can pile up and become a major liability unless your service is actively looking for errors and correcting them.
We recommend conducting regular internal and external audits to catch these issues. At MCS, we offer audits of a randomized sample of paid claims and provide a detailed report to your service. This process can help your service identify blind spots in your documentation and show your good faith and intent to actively conduct compliance activities and submit valid claims to Medicare.
Quality Assurance (QA) Process: The OIG recommends an internal QA program to ensure compliant documentation for billing is being provided and to ensure clinically compliant procedures are being conducted on transports. The QA process works on the front end prior to billing to help check for properly documented claims. A good QA program has the added benefit of streamlining the billing process and gets claims paid faster.
Many ambulance services treat their billing company as their QA process. Doing this slows the billing process by causing claims to be sent back and forth to obtain or correct documentation that wasn’t originally provided. Also, billing companies aren’t QA teams and some issues with documentation may not be discovered, making those claims susceptible to audits in the future. In both cases, the lack of a QA process can hurt your service’s bottom line.
Training: All ambulance services should conduct regular training for their employees. Topics include compliant documentation, information about your service’s compliance program and policies and procedures, and other job specific functions for employees. A lack of proper training on compliance can impact the quality of your service’s documentation and understanding of your service’s policies and procedures in other areas.
We recommend and offer interactive online training on both compliance and other issues including HIPAA. Conducting regular training on compliance helps to build your service’s compliant culture and shows you care.
Policies and Procedures: The OIG also recommends written policies and procedures which have been reviewed and approved by your service. These are the foundational pieces of your compliance program and the best way to make sure everyone has access to and understands the goals of your compliance program.
We offer support for our clients with sample policies and procedures for a compliance program. With these samples you can tailor the policies and procedures to your service’s needs. Without policies and procedures your service won’t have a compliance program.
While we have put a spotlight on ambulance services with third party billing companies, the importance of a compliance program applies equally to services who bill in-house.
We believe incorporating the OIG’s compliance program guidance into your service’s processes will not only protect your service from the risk of an audit but will increase income over time.
If you have any questions or would like to learn more about the services we offer to assist your service in creating or improving your compliance program, please reach out using the contact form.