Developing and maintaining a strong inpatient coding compliance program is critical for health systems of all sizes. Constantly changing guidelines, regulations, policies and standards make it important to have a comprehensive process in place for continuing to monitor your organization’s compliance. Failure to do so can have lasting implications on your revenue cycle and could lead to significant financial penalties for inaccurate coding or non-compliant processes.
1. Team – There’s no ‘I’ in team, so a team approach and a shared sense of accountability for your compliance program is critical. Compliance, coding and CDI teams should work together to ensure your processes, policies and ongoing process improvement plans are all headed in the same direction. Many organizations leverage both internal and external resources for inpatient coding compliance. By blending your internal team’s in-depth understanding of your organization combined with an industry leader’s perspective and knowledge of national trends, changes in ICD-10 guidelines, as well as those areas most likely to be scrutinized by the Office of Inspector General can provide great value.
2. Process & Policies – Every organization should have a comprehensive compliance policy in place as it relates to inpatient coding, which should outline expectations for your physicians and/or medical staff members, internal staff and others who play a role in maintaining your compliance with state and federal coding guidelines. The policy should be based on the AHIMA Code of Ethics, AHIMA Standards of Ethical Coding, ICD-10 guidelines and your internal processes. Your policy should be reviewed annually and updated according to any changes in guidelines or standards. Coding audits – whether performed internally or externally (or a hybrid approach) should be done throughout the year and can play a key role in your compliance plan.
3. Continuing Education – When it comes to inpatient coding, ongoing process improvement is a critical element of any effective compliance program. Even the highest-performing organizations will identify trends and opportunities for improvement that should be shared across the enterprise and translated into educational and/or training initiatives. Ensure your coders have continuing education as part of their job description and work it into their annual performance review. The same goes for physicians and providers – ensuring your medical staff are up-to-speed on the latest guidelines as it relates to clinical documentation should be an annual requirement – rather than a “nice to have.” Working together, your coders and providers can have a significant impact on improving your organization’s performance, so hardwiring training and education into your policies will go a long way into enhancing your revenue cycle and compliance efforts.
4. Identification of Trends – At its most basic level, a compliance program must be constantly evaluating data, performance and identifying trends in order to be successful. Your compliance program should include tools and technology designed to provide high-level reporting to all members of the team. Robust dashboarding tools like GeBBS’ iCode Assurance can help organizations improve performance, identify revenue impact and opportunities and help you set benchmarks and achievable metrics to promote continuous improvement.
5. Corrective Action Plan – Even the very best compliance policies and plans can’t be successful if there’s no plan for what to do when performance is less than stellar. Ensuring your policies include a process for investigating recurring issues – as well as a defined process for how to handle these issues if and when they do occur will be critical to your success. Getting your providers, staff and compliance teams involved in developing these policies can help with buy-in and adoption. Communication of these policies before issues arise will also help. Finally, making the process for corrective action as non-punitive as possible will allow all members of the team to work together to make compliance and continuous improvement a collaborative process for all involved.
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