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7-2 Final Project Submission: Monthly Compliance Report
HIM 360
SNHU
February 25,2022
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Preface
The purpose of the monthly compliance report is to capture the deficiencies that
exist in the coding process in the SNHU Medical Clinic. A detailed compliance plan has
been presented in the report with suitable recommendations in necessary areas. On an
annual basis SNHU performs auditing of provider charts for maintaining and ensuring
coding compliance. A generated audit summary report was examined to locate
inefficiencies. It helped to identify areas that needed improvement so that the goals of the
SNHU Medical Clinic can be attained. The compliance plan that has been designed can
play an integral role to strengthen the current compliance framework in the facility. It can
play to strengthen the current compliance approach.
A detailed evaluation has been conducted by focusing on a diverse range of areas such as
the outcome, coding guidelines, review process, as well as EHR System. Each of these
areas have helped to understand the quality of compliance relating to coding practices in
the clinical facility. The outcome of the provider chart audits have revealed that there
were certain errors due to which several charts failed to meet the documentation level for
the ‘Family Practice Charges Claims’ codes. In the health care setting, it is necessary to
understand the importance of codes and suitable coding guidelines as it can have a direct
implication on the quality of care that is delivered to the patients. In the health care
context, the thorough evaluation process that was adopted revealed that there was a need
to revise the existing review process relating to clinical documentation. This is because a
proper review of documentation can help to identify gaps. In the health setting it can add
value by ensuring that close attention is paid to details and vital information.
Additionally, the staff must be given adequate training on the application of suitable
codes. m
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The importance of a well-functional compliance program has also been captured since it
can play an instrumental role in the detecting, preventing, and responding to requirements
relating to federal and state laws. In order to ensure that proper compliance is in place it
is critical to understand the importance of the Office of Inspector General (OIG)
specifications. A broad range of recommendations has been made relating to diverse areas
such as enhancing the coding process, improving the clinical documentation processes,
focusing on the quality measures, focusing on the training aspects of the employees in the
health care facility, identification of instances of fraud or abuse, introduction of additional
technology and additional resources and having a well-defined audit schedule in place and
conducting detailed evaluation. The recommendations have been designed at a
comprehensive level so that the coding practices in SNHU Medical Clinic can be
strengthened and it can comply with suitable and relevant coding standards and
guidelines. For strengthening the coding process in an integrated manner, the staff has to
be trained and educated relating to the latest coding practices. It is highly critical to
ensure that they comply with the necessary requirements and follow a systematic coding
approach while carrying out their roles and responsibilities. Similarly, the integration of
new technology such as an electronic software program can be critical to automate the
current auditing activity since it can help to eliminate errors that may arise due to the
manual auditing process. In the final compliance report the coding process of the clinic
has been examined. Additionally, stress has been laid on the documentation and
compliance aspects that must be taken into consideration in the health care setting.
Evaluation
Accurate and complete medical records is imperative for the success of healthcare
organizations. The lack of accurate and complete medical records can affect the
organization’s ability to meet the necessary standards and regulations, hamper patient care
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as well as satisfaction level, and lead to poor financial performance (Giannangelo, 2019).
Comprehensive documentation ensures that medical records aid in billing to payers for the
services provided. A medical record audit must be performed to ensure that providers are
accurately following documentation procedures. The audit can help in locating
documentation-related weaknesses and help healthcare organizations to ascertain the
educational needs of the providers.
An annual audit was conducted in 2019 as a part of Southern New Hampshire
University’s coding compliance process relating to ‘Family Practice Charges Claims.’
Every provider’s previous 90 days encounter was used to create a table. Then ten random
charts per provider were chosen by using the evaluation and management codes relating
to new and existing patient office visits. It was followed by copying or printing of the
medical documentation on these charts which were sent to the auditor for evaluation
purposes. The exceptions located during the audit process were captured in a spreadsheet.
In the summary section of the spreadsheet, the charts that did not meet the necessary
documentation level were listed.
The audit process revealed that out of 150 charts that were evaluated, 9 charts
failed to meet the required documentation standard for the code that was billed. These 9
charts had used the evaluation and management code 99214(Oachs & Watters, 2016). The
encounters 502, 2426, 3255, 4884, 5157, 5556, and 6666 supported the evaluation and
management code 99213. The encounters 4612 and 6998 supported the evaluation and
management code 99212. They wrongly billed the payers $ 1,737.00 instead of $1,066.00.
Thus, the payers were overbilled by $ 671.00.
The review of seven operative notes including 21A, 22A, 23A, 24B, 25C, 26C and
27C was done for ensuring nothing was missing.5 of them had missing components. The
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observation of the operative notes at the comprehensive level is descent; however, the
documentation lacks consistency. Provider 4’s documentation is extremely inconsistent as
his 3 charts had 10 errors.
The healthcare organization must offer additional training to providers, physicians
and medical staff relating to accurate documentation standards, reviewing of policies and
procedures, and safety. It will help in meeting the standards set by The Joint Commission
and help to pass future audits. It will help reduce reimbursement delays, facilitate correct
coding and maximize reimbursement. By ensuring that accurate documentation enters
medical records, correct services can be billed to payers(Oachs & Watters, 2016). A
billing specialist must review the provider’s documentation for ensuring it supports the
chosen code. Annual training must be provided to the medical billing and coding staff so
that they can update their knowledge of the latest billing policies, coding standards and
other areas. In case coders are confused by any documentation element they must get it
clarified from the providers.
The E/M code reporting is done based on history, physical examination and medical
decision-making (Giannangelo, 2019). While reviewing the summary of the audit it was
observed that the providers struggled to ascertain the medical decision-making level for
each patient. It caused the nine charts to fail to meet the documentation level for the
chosen codes. Giannangelo (2019) has stated that medical decision-making is highly
cognitive of the three criteria for assessing E/M codes and it is extremely difficult to
quantify (p.73). The four levels of medical decision-making are high complexity,
moderate complexity, low complexity and straightforward. 99214 is the E/M code that
was inaccurately used in the 9 charts and the level of medical decision-making is
moderate complexity. The audit’s summary section shows that 7 out of 9 charts have
alow complexity medical decision-making level. The other two charts belong to the
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straightforward level category. The organization must ensure that the providers have
knowledge of factors that help to determine the level of medical decision-making. The
chart presented below shows how the medical decision-making level is ascertained. In
documentation, two out of three factors must be included for coding the level of medical
decision-making. The charts with discrepancies must be rectified by the provider so that
medical coders can reassign accurate codes and mend overpayment problems.
Medical Decision-making levels
Complexity levels
Diagnosis or
management
options (#)
Complexity of
data reviewed
Risk of
complications,
morbidity or
mortality
Straightforward
Minimal
None or
minimal
Minimal
Low
Limited
Limited
Low
Moderate
Multiple
Multiple
Moderate
High
Extensive
Extensive
High
(Giannangelo, 2019 p.74)
As part of SNHU’s coding compliance, the annual audit of provider’s chart must
be continued. The Office of the Inspector General (OIG) will advise the healthcare
organization on recognizing issues and addressing them. The OIG’s coding accuracy rate
is 95 % and they expect all providers to maintain it. The development and
implementation of a clinical documentation improvement (CDI) program is necessary.
Oachs and Watters (2016) have stated that as per the American Health Information
Management Association (AHIMA), CDI’s purpose is to initiate concurrent and suitable
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retrospective reviews of medical records for incomplete, conflicting or nonspecific
provider documentation (p.267). This program will enable the organization to ensure
alignment between the medical records and appropriate regulations and guidelines. It will
aid in patient record completion, providing education, enhancing provider documentation
and coding and patient care. m m
The CDI program can be successful if everyone works cohesively in the healthcare
organization. A successful CDI program can facilitate progress towards value-based care
instead of fee-for-service model. An EHR system with pre-designed data elements will
help providers to enhance documentation quality and overall efficiency. The program
enables providers to document when a patient is being cared for. Thus CDI reviewers can
review the records when they are being created. So, errors can be identified faster and
providers and coders can spend extra time on other patients which can increase the
workflow. Providers must understand that CDI helps to ensure proper documentation is in
place for supporting billed codes. Documentation acts as evidence relating to why a code
is used for billing a payer. Provision of training on documentation and CDI process can
help professionals to understand their roles(Quinn, 2017). Training can be provided in the
form of real, practical documentation examples, learning of specific documentation for
specific coding systems, use of templates for documentation problem areas, discussion on
important documentation, CDI process and how they work, and creating posters, and
newsletters for increasing awareness level of respective roles and creating pocket cars for
reference purpose (Oachs & Watters, 2016 p. 275). These training tools and techniques
must be regularly monitored and they must be offered regularly or as required by the
staff.
The prevalent EHR system is effective for documentation and offers suitable
criteria for quality measures reporting. The issues arise since the providers struggle to use
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the system for charting, rush the charting process or do not pay attention or lack the
understanding of what has to be charted. The EHR system must be upgraded to include
charting services techniques so that providers’ time spent on charting can be saved. A
checklist must be included to ensure providers document comprehensive
information(Quinn, 2017). The system must encompass a clinical decision support (CDS)
component to locate errors and boost accuracy in documentation. Some CDS tools are
computerized alerts, templates, reminders (Quinn, 2017). The billing and coding software
of the system can minimize coding errors. In spite of using technology, the possibility of
errors exists. Training of providers and medical staff on EHR system and documentation
is imperative. The entire healthcare staff must understand the organization’s policies and
procedures and medical standards. The policies and procedures must list staff
expectations, training details, etc. The organization must ensure that audit is continuously
conducted, provider documentations are monitored, and training is provided to the staff.
Adopting such holistic measures can ensure the success of the healthcare organization.
Compliance and Recommendations
I. Compliance
A.
A compliance program refers to formalized effort in order to detect, prevent, and
respond to conduct the operation of a business that is inconsistent with state and federal
laws(Compliance program description - main line health, 2021). The importance of
compliance programs is that it ensures that the organizations adhere to the applicable state
as well as federal laws and other requirements of the healthcare sector. It helps in
protecting practices against abuse, waste, fraud, and other liability areas. One of the
significant benefits of having a formal compliance program is that it helps in establishing
an organizational culture that promotes detection, resolution, and prevention of conduct
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not conforming to the law or ethical policies of the organization. Another prominent
benefit is that it helps in reducing the risk of improper or unlawful conduct. Not having a
compliance program in place can result in a number of disruptions in the delivery of
patient care. It may even result in fines and other legal consequences.
B.
Office of Inspector General (OIG) plays an important role in ensuring honesty and
integrity in the healthcare institutions in the US. The vital elements of OIG classifications
include written procedures and policies, effective education and training, effective lines of
communication, designated compliance committee and compliance officer, internal
auditing and monitoring, prompt response to identified problems, andenforcement of
standards.The formal compliance program that is in place has been carefully analyzed. It
is found that the compliance program meets all the requirements of the OIG
specifications. It is appropriate for the specific clinic type and meets the needs of the
facility.
C.
In case the compliance plan is not adhered to, it can result in several negative
consequences. It can affect the delivery of quality care to the patients in the healthcare
setting. Moreover, it may even give rise to several legal issues. To ensure optimum
compliance with the plan, the organization needs to monitor it carefully. For effective
monitoring, the goals can be broken down into several manageable steps. Then, the steps
can be monitored with the help of compliance staff, either from outside or inside the
facility, as per the requirement. A change that needs to be done in order to improve the
usefulness of the compliance program is to ensure that there is a dedicated person for
each department. This will help in lowering the chances of any confusion at the time of
audit.
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II. Recommendation
A.
The quality of clinical coding is becoming increasingly important in the healthcare
setting(Jg et al., 1970). In order to enhance the coding process in the organization, there
is a need of making a number of adjustments. The staff members of the healthcare
organization must be provided with additional education to allow them to gain a better
understanding of the complete coding process. They need to be provided with sufficient
information relating to the coding guidelines. It also includes the HCPCS Level I and II.
Moreover, they must also be given education relating to documentation guidelines specific
for E/M services as well as NCCI PTP edits. It will help them in becoming more familiar
with the coding process and avoiding the chances of potential errors.
B.
Another improvement in the clinical documentation processes is the application of
SNOMED CT. It is a suite of designated standards used in the US Federal Government
systems for clinical health information exchange(National Institutes of Health, 2021). It is
a comprehensive clinical healthcare terminology that enables meaning-based retrieval. The
system breaks down the terminology on the basis of procedures, diagnosis, symptoms,
signs, and causesof injury. It also has description tables that offer flexibility to express
different clinical concepts. With an effective coding program, it becomes easy to reduce
errors and enhance the accuracy of claims. SNOMED CT helps in enhancing the quality
of clinical reporting. It helps in effective sharing as well as the recording of clinical data
like a list of patient problems and medical histories in the EHRs. It helps in enhancing
healthcare quality measures by improving effectiveness, timeliness, and safety of care. It
also enhances the overall patient outcomes by facilitating early identification of health
issues, effective monitoring of patient health, and responding to changes in clinical
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practices. It allows targeted and accurate access to healthcare information, reducing the
chances of errors and costly duplications.
C.
In reference to quality measures, these improvements can result in more accurate
determination of a patient population through the tracking of procedural trends and
diagnosis on the basis of simple criteria such as gender, age, and more.
D.
In order to meet the requirements of healthcare data reporting and to attain the
standards of the industry, it is important to provide the medical staff with appropriate
training. For effective training of medical staff, a refreshed presentation can be created. It
will ensure that all the staff members are well equipped with the basic tools in order to
meet compliance goals. All the staff members need to be properly certified. In case they
are not certified, they must be provided with the essential resources in order to ensure
better compliance. Chart audits can be conducted on a regular basis,and then the final
report can be submitted to the compliance committee. It will help in determining whether
the medical staff and healthcare providers require more education or not.
E.
Fraud, as well as abuse,is frowned upon in the healthcare industry. Fraud can be
defined as the intentional misinterpretation of documentation that leads to unauthorized
payment or benefit. Some of the prominent examples of fraud are misrepresenting dates,
submitting claims of specific services that are not rendered, and misinterpretation of
service descriptions or duration. Accuse can be defined as the act performed beyond the
acceptable standards of medical necessity or professional conduct. In case the auditors
suspect any kind of abuse or fraud, it is important to document who has committed the
fraud or abuse. In addition, it is also essential to note when and where the fraud or abuse
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was committed. Other important details need to be noted. If the auditors suspect any kind
of abuse or fraud, they need to report the authorities, such as the Department of Health
and Human Services.
F.
In order to improve the functions of the current process in the clinic, it is
important to implement the right technology. For this clinic, it is important to avail of an
upgrade of the technology. However, as the amount of errors is very small, it may not be
required to change the workflows. In terms of technology, a sandbox environment can be
very beneficial. It is especially beneficial for testing procedures and scenarios. This can
provide the staff members with a preview of kinks that must be worked out without
causing any disruption to the current workflow. The final product is implemented.
G.
A number of additional resources may be required for the effective implementation
of the recommended technology. One of the important resources in training. Training
sessions, as well as webinars, need to be conducted before the implementation of the
recommended technology. It would be essential in order to ensure that all the staff
members, as well as healthcare providers are able to properly understand the technology
effectively. It also provides them with an opportunity to ask their doubts and questions
relating to the technology and avail appropriate answers. It will enable them to gain
insights into what they can expect in the technology update. As the staff members get
familiar with the system, it will reduce their pressure of completing daily tasks in a
timely manner. Another resource that may be required is budget. The budget needs to be
expanded. The healthcare organizations may also consider grants in order to avail the
required funding.
H.
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The audits are to be conducted on a regular basis. It should be done at an interval
of ninety days. However, in order to conduct the audits effectively, it is important to have
a proper schedule. It will help in conducting the audit in a systematic manner.
I.
After evaluation, there would not be a need to modify the workflow process in the
clinic. A technology update would be sufficient to get the desired outcomes.
The compliance programs play an important role in the healthcare setting. It enhances the
quality of care and ensures adherence to state and federal laws. A strict and formal
compliance plan is essential for the proper functioning of the organization. A number of
recommendations have been given relating to the coding process, necessary
improvements, quality measures, training, technology, resources, and audits.
Conclusion
The detailed evaluation of the coding process of the SNHU Medical Clinic has
been carried out since the proper maintaining of comprehensive and correct medical
records is of paramount importance for each and every health care organization. It can
have a direct and significant impact on its overall operations as well as the quality of care
that is offered to patients. Based on the thorough assessment of the coding practices, a
diverse range of recommendations has been made that can help to strengthen its
compliance with the latest and relevant coding requirements such as adopting new
technology, offering training opportunities to the staff members and conducting regular
audit activities.
On the basis of the in-depth assessment, it can be concluded that the overall status
of the coding program of SNHU Medical Clinic is decent. However, since a number of
errors were located in the charts it is safe to state that the current coding program can be
further improved. High emphasis must be given to medical staff training relating to
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coding so that the instances of coding errors can be eliminated, and the current status can
be further enhanced Currently the health care entity maintains compliance with
healthcare rules and regulations, but the coding compliance program can be strengthened
to enhance compliance. Inspite of laying emphasis on compliance, there existed errors and
loopholes in the current system in terms of coding due to which there was a lack of
complete and correct medical records. The Audit Summary captured a total of 40 errors
and thus the accuracy level was 78 %. The comprehensive evaluation that was carried out
revealed that there was scope for the health care organization to provide additional
training to the medical staff members, physicians, and others so that they could broaden
their insight into documentation standards and requirement, reviewing of policies and
coding practices. The providers need to be trained for making quality medical-related
decisions while working on coding. As codes may undergo change after a certain period,
the management of the SNHU Medical Clinic must make sure that the staff is trained on
a frequent basis so that their knowledge on coding can be expanded on an ongoing basis.
The audit activity that was conducted revealed that training was a key area that could be
increased to strengthen the current coding practices and enhance the level of compliance.
SNHU must focus on regularly monitoring the program to prevent issues and identify the
training needs of its health care staff members. For improving the functions of the current
processes in the clinical facility, technology must be integrated at diverse levels. It can
play an instrumental role to enhance the efficiency and productivity of the organization. It
has been identified that an audit software can be introduced in the health care facility so
that necessary healthcare data reporting requirements can be followed. The introduction of
the electronic software program in the health care setting can basically help to automate
the current processes and help to keep a tan on the data and information that is captured
by the medical staff and physicians. The current coding practices and compliance that is
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adopted in the SNHU Medical Clinic needs to be improved so that the facility can carry
out its functions more effectively. The facility must adopt a comprehensive approach by
focusing on the coding guidelines, training of the staff, integration of new technology and
use of suitable resources and revising the review policies so that the coding process can
be improved. Similarly, a well-defined compliance program must be introduced that can
aid the clinical facility to adhere to the appropriate health care rules and regulations.
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