The core elements
The government's guidance lists the elements of an effective compliance program. For a small group, it boils down to:
- Written policies, including how you bill
- Someone responsible for compliance
- Training for everyone, once a year
- A way for people to raise concerns
- Regular checks of your billing
- Fixing problems when you find them, including paying back money you shouldn't have received
Start with billing audits
Check a sample of cases every quarter: time, modifiers, medical direction and documentation. See preparing for audits.
If you find a problem
Fix it, work out how far back it goes, and talk to a healthcare lawyer about repayment rules. Overpayments generally have to be returned within set deadlines.
This article is general information, not billing, legal or tax advice. Payer rules change; always check current guidance.
Sources
Free checklist
Anesthesia Billing Audit Checklist
Checks to find out whether your billing is collecting everything it should. Print it, work through it, and see where the gaps are.
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