Medical Quality Confusion Reigns
By Dr. David Edward Marcinko; MBA, CMP™
Doctors, medical staff, healthcare administrators and patients can often get confused regarding what issues need reporting through their compliance mechanisms [terminology and definitions].
www.HealthDictionarySeries.com
For example, some staff members may think that every “complaint” should get reported through the system. Since the focus of this program is geared more to concerns of fraud and abuse, the staff needs to be educated about what should be reported and what should not.
Smaller Practices
In small healthcare organizations, education on “compliance-related” issues could be part of regular staff meetings or individual meetings with the compliance coordinator. Staff knowledge of the organization’s expectations can be reinforced on a consistent basis. This will avoid issues that larger organizations have been having, where the compliance hotlines have been used for customer complaints and labor issues.
Assessment
If a healthcare entity notices that inappropriate issues or complaints are being brought up through the compliance program, leadership should respond by evaluating the reasons why this is occurring and look at putting in actions to correct the confusion.
Conclusion
We hope you will opine on our concepts of health administrative definitional-stability concerning complaints versus compliance; please comment.
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Healthcare Organizations: www.HealthcareFinancials.com
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Physician Advisors: www.CertifiedMedicalPlanner.com
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Filed under: Health Law & Policy, Practice Management, Quality Initiatives, Risk Management |














Dr. Marcinko.
Nice job with this post and ME-P blog.
Here are some of the key provisions in the Patient Protection and Affordable Care Act, as modified by the Health Care and Education Reconciliation Act of 2010 (collectively, the “Health Care Reform Act”). This comment summarizes and clarifies the timely claims submission compliance requirements, based on a recent CMS Transmittal.
• For services furnished on or after January 1, 2010, all Medicare providers and suppliers must submit claims to their Medicare Administrative Contractors within one (1) year of the date of service. CMS, in a Transmittal issued on May 7, 2010, has interpreted this to mean that claims must be submitted within 365 days of the date of service. For example, if a service is furnished on March 15, 2010, then the claim must be submitted to Medicare by March 15, 2011 (Formerly, providers and suppliers that provided services had at least 15 to 27 months to submit their claims).
• The CMS Transmittal instructing the Medicare Administrative Contractors on implementing this change is available at http://www.cms.gov/transmittals/downloads/R697OTN.pdf.
• The CMS is expected to propose an interim rule interpreting this new law and addressing whether any exceptions to the filing deadlines will be permitted. The CMS’s interpretation of this billing change, specifically the requirement that the claim must be submitted within one (1) “calendar year after the date of service”, is a change from its previous interpretation of this same phrase under the prior law. Previously, CMS had interpreted “calendar year” as the year ending on December 31st following the date of service, and not as a 365-day period from the date of service. We will keep you apprised of these changes.
Of course, one should evaluate claims submission practices and/or billing vendor contracts to make sure you are compliant with this CMS Transmittal.
MacIntire
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