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It is in the best interest of the organization to have the board _______. ✔✔...take an active rather
than a passive role in compliance.
Six tips for saving on future costs of compliance. ✔✔1. embed quality into existing processes
centralize common processes and controls
improve human resources infrastructures
improve information systems processes
emphasize training
monitor marketing and compensation
Baseline Audit Process ✔✔1. outline the current operational standards
identify real and potential weaknesses
offer recommendations
,Compliance Program - Measures of Effectiveness ✔✔1. staff knowledge
all 7 elements included
comparing issues year to year
tracking and trending complaints
tracking corrective actions
reviewing current audits
educational session pre and post tests
tracking bill denials
organizational survey results
audit results
compliance topics on department/organization agendas
Modifier ✔✔a two digit alpha/numeric code used in conjunction with CPT or HCPCS codes that
may increase or decrease reimbursement
gives new meaning to the code
,International Classification of Diseases (ICD) ✔✔a statistical classification system that arranges
diseases and injuries into groups according to established criteria (signs and symptoms)
Current Procedural Terminology (CPT) ✔✔American Medical Association publishes and
maintains this coding system
Federal Sentencing Guidelines - Culpability Score Aggravating Factors ✔✔1. upper-level
employee participates, condones, or ignores offense
repeat offense
hinder investigation
awareness and tolerance of violation is pervasive
Federal Sentencing Guidelines - Culpability Score Mitigating Factors ✔✔1. effective compliance
program
reported promptly
cooperation with investigation
accept responsibility
, Federal Sentencing Guidelines - Seven Elements of an Effective Compliance Program ✔✔1.
written standards of conduct Chief
Compliance Officer
effective education and training
audits and evaluations to monitor compliance
reporting processes and procedures for complaints
appropriate disciplinary mechanisms
investigation and remediation of systematic problems
The only thing worse than not having a policy is... ✔✔...having a policy and not following it.
Medicare reimbursement - hospital inpatient codes ✔✔International Classification of Diseases
(ICD)
Medicare reimbursement - physician codes ✔✔Current Procedural Technology (CPT)
Questions to guide the scope of an internal investigation. ✔✔1. What is the origin of the issue?
When did the issue originate?