COMPLIANCE AND THE REVENUE CYCLE

1
COMPLIANCE AND THE REVENUE CYCLE What Does
the Compliance Officer Need to Understand About
the Risks?

• PRESENTED BY TAUNA SHELTON MHSM,MS,CHC
• REGIONAL DIRECTOR COMPLIANCE AND PRIVACY
• THR

2
REVENUE CYCLE PROCESS

• Who is involved in the Revenue Cycle?
• Scheduling Pre-Registration
• Registration Verification
• Financial Counseling
• Charge Capture
• Documentation Coding
• Bed Control
• Billing
• Payment Posting
• Account Follow-Up
• A/R Management
• Contracting
• Medical Records/ HIM
• Case Management
• Utilization Review
• IT
• Clinical Areas

3
EACH DEPARTMENT PROVIDES OPPORTUNITY FOR ERROR
AND RISK

• Scheduling Pre-Registration patient screening
  for demographic information, verification of
  orders, insurance, insurance approval for OP
  procedures will ABN be needed for Medicare
  patient because diagnostic test does not meet
  medical necessity?
• Registration Verification verifying patient
  identity, insurance card (Is patient the person
  presented, or is this a fraudulent use of
  identification to obtain services by using
  someone elses insurance card?) (Medicaid /
  Medicare), fraud perpetuated via follow up
  services? or case of identity theft by patient
  or even entity staff ?

4
ERROR OR RISK (cont)

• Financial Counseling financial screening for
  self pays or charity care supported by
  organizational Charity Care Policy and state laws
• Charge Capture are the correct charges for
  services provided, including number of charges
  actually being placed onto the patients account
  (medications, procedures) including overcharging,
  undercharging, lost charges or charging for
  services not provided?

5
ERROR AND RISK (cont)

• Documentation Coding Physician notes, Nurses
  notes, ancillary staff notes supporting the
  ordered services detailed enough to provide
  substantiation to an auditor ?
• Bed Control placement of patient in correct bed
  based upon order timed by physician, patient
  transfers?
• Billing billing the correct patient on the
  correct account, correct number of services?
• CHARGEMASTER updates for each service, billing
  edits loaded, charge capture issues?

6
ERROR AND RISK (cont)

• Payment Posting payments posted on correct
  account, payments applied to correct account ,
  credit balances on account worked?
• Account Follow-Up accounts worked with patient
  friendly guidelines and following state
  collection laws?
• A/R Management as accounts age are they being
  worked to resolve credit balances, bad debt and
  appropriate communications with payers?

7
ERROR OR RISK (cont)

• Contracting are payments being monitored by the
  CBO and the Contracting Department for proper
  payments based upon the written contract payment
  guidelines? are edits in place for both the
  entity and the payer?
• Medical Records / HIM coding by CCI guidelines,
  backlog in coding, increased query of physicians
  for confirmation of documentation, quality self
  department checks?

8
ERROR AND RISK (cont)

• Case Management are appropriate InterQual or
  MR guidelines used for placement of patient into
  appropriate level of service based upon medical
  necessity and severity, observation or inpatient
  services required?
• Risk Management high profile cases being checked
  for billing and compliance issues, as well as,
  the current risk occurrence issue?

9
ERROR OR RISK (cont)

• IT system supporting all needs of clinical
  staff, billing staff, HIM staff EHR being used,
  ability for tracking audit trails?
• Clinical Areas continuous communication on
  billing and charging changes, charge audits?

10
REVENUE CYCLE DRILL DOWN

• FOCUS TODAY ON
• NEED FOR POLICIES
• CHARGEMASTER
• CENTRAL BUSINESS OFFICE and CREDIT BALANCES
• CHANGES TO COME IMPACTING REVENUE AND OPERATIONS

11
SYSTEM / ENTITY POLICIES SUPPORTING THE REVENUE
CYCLE

• CHARGE CAPTURE POLICIES provide guidance for all
  staff involved in the revenue cycle who document
  charges, input charges, monitor charges or audit
  charges
• CHARGEMASTER POLICIES provide guidance for all
  staff responsible for requesting new services,
  new charges or changes in existing charges with
  the addition of the appropriate CPT codes

12
POLICIES (cont)

• BILLING POLICIES provide guidance to all staff
  associated with billing on how to handle
  discrepancies, credit balances, bad debt, A/R and
  billing cycle requirements
• COMPLIANCE POLICIES provide government based
  guidance to assist all system / entity staff with
  concerns of illegal activities, billing concerns,
  fraud issues or simple questions

13
COMPLIANCE BILLING AND OPERATIONAL LAWS

• MEDICARE REQUIREMENTS
• MEDICAID REQUIREMENTS
• FALSE CLAIMS ACT
• STARK LAW

14
SIGNIFICANT LAWS GOVERNING FEDERAL HEALTHCARE
PROGRAMS

• ANTIKICKBACK STATUTE Authorizes criminal and
  civil penalties against anyone who knowingly and
  willfully solicits, receives, offers, or pays
  remuneration, in cash or in kind, to induce or in
  return for referrals for services payable under
  federal healthcare programs

15
SIGNIFICANT LAWS (cont)

• Civil Monetary Penalties Law Holds a person or
  entity subject to penalties for submitting a
  false claim or a claim that should have been
  known to be false, allows a penalty of up to
  10,000 for each service or item falsely or
  fraudulently claimed and an assessment of up to
  three times the amount claimed and potential
  exclusion from the federal healthcare program or
  programs

16
SIGNIFICANT LAWS (cont)

• False Claims Act Holds a person or entity liable
  for up to treble damages and up to 11,000 for
  each false claim it submits or causes to be
  submitted to a federal healthcare program, does
  not require a specific intent to defraud and
  includes a provision for Qui Tam or whistleblower
  suits, which allow individuals to file suit on
  behalf of the U.S. government

17
SIGNIFICANT LAWS (cont)

• Health Insurance Portability and Accountability
  Act of 1996 Addresses use and disclosure of
  individuals health information (protected health
  information) by hospitals and other covered
  entities includes standards for individuals
  privacy rights and how their health information
  is used.

18
SIGNIFICANT LAWS (cont)

• Physician self-referral law (Stark Law)
  Prohibits hospitals from submitting to Medicare
  any claim for designated health service if the
  referral of the DHS is generated by a physician
  who has a prohibited financial relationship with
  the hospital. Hospitals and physicians who
  violate the Stark law are subject to civil
  monetary penalties and exclusion from federal
  healthcare programs

19
STARK III UPDATE

• On September 5, 2007 CMS issued final regulation
  outlining the third phase of regulations
  prohibiting physician self-referral. This
  prohibits physicians from referring Medicare
  patients for certain items, services and tests
  provided by businesses in which they or their
  immediate family members have a financial
  interest. This regulation is the third part of
  the final regulations implementing the physician
  self-referral prohibition commonly referred to as
  the Stark law taking effect on December 4, 2007

20
STARK III (cont)

• Redefines arrangements between hospitals and
  individual members of group medical practices as
  direct rather than indirect compensation
  eliminates the safe harbor methodology for
  calculating fair market value for hourly
  physician service and create additional
  flexibility for rural hospitals in recruiting and
  retaining physicians. This rule makes no changes
  to the in-office ancillary services exemption,
  but cites this area as a possible target for
  future rulemaking.

21
PATIENT FINANCIAL SERVICES

• BILLING LAWS
• BILLING CYCLE
• EDITS
• BAD DEBT
• CREDIT BALANCES
• CHARITY CARE
• WRITE OFFS

22
Financial Risks Associated with Credit Balances

• FRAUD
• WASTED MAN-HOURS AND PROCESSING COSTS
• MIS-STATED PROFIT
• LOST BILLING OPPORTUNITIES
• MEDICARE PENALTIES

23
CAUSES OF CREDIT BALANCES

• Mis-posted allowances incorrect estimates of
  cash amounts due
• Duplicate payments
• Charge credits subsequent to billing
• Full payments by both primary and secondary
  insurers
• Up-front collections incorrect estimates of
  patient liability

24
STATS ON HOSPITAL RESOLUTION

• Most credit balances are not the result of
  overpayments
• One third resolved result in a refund to patient
  or payer
• One half are mis-posted allowances that need to
  be reversed on the PA system and dont require
  refunds
• Payer contracts can result in incorrect rates and
  terms loaded into the hospital system these
  create understatements of a hospitals
  profitability and AR

25
ADDITIONAL SOURCES OF ERRORS

• Errors occur when a claim is paid twice by a
  payer
• Problems created by manual errors, system errors
  or a combination of both
• Results of better point-of-service collections
  better up-front collections create higher volume
  for credit balances
• Over-estimates of what is owed in a Managed Care
  environment

26
RISKS OF CREDIT BALANCES

• Real risks posed by
• Medicare penalties
• Wasted time
• Lost payment opportunities

27
MEDICARE PENALTIES

• Suspension of Medicare payments caused by
  non-compliance with federal regulations
  concerning credit balances
• Fines
• Imprisonment
• CMS requires hospitals report all Medicare credit
  balance overpayment accounts quarterly using form
  CMS-838, which must be signed and attested to by
  an officer of the hospital, specifically by the
  CFO or CEO.

28
MEDICARE PENALTIES (cont.)

• Documentation must be maintained that shows that
  each patient record with a credit balance was
  reviewed to determine if any credit balances are
  attributable to Medicare
• Most hospitals do not have an effective means to
  ensure compliance which means several credit
  balance accounts can be present
• Risky for the CFO because after signing the
  Medicare Credit Balance Report, he/she is
  attesting to the fact that all of the hospitals
  credits have been reviewed
• Credit balances are NOT a profit center!

29
LOST BILLING OPPORTUNITIES

• Once accounts are analyzed and adjusted, billing
  opportunities to generate additional cash
  receipts are often revealed
• Amounts due from payers and patients have been
  hidden by the credit balances
• Failure to analyze credit balances in a timely
  fashion can result in permanent lost cash

30
FRAUD

• High volume of refund checks issued by large
  hospitals to patients, insurance companies and
  vendors make it impossible for controllers to
  scrutinize verify each refund
• Because refund checks pass through many hands,
  they can end up in the hands of the originator of
  the request
• Credit balances and the refund processes are ripe
  for fraudulent activity making hospitals
  exposed to financial losses and corporate
  embarrassment
• Refund checks can be misappropriated because of
  weak internal controls and because the intended
  receiving parties are not aware that they are due
  a refund check

31
NEGATIVE PRESS

• Unresolved credit balances can trigger management
  letter comments to a hospitals board of
  directors noting items of concern
• Credit balances understate an organizations
  profit and the AR

32
COMMON MISCONCEPTIONS

• Setting high dollar thresholds for account
  management creates a time-bomb effectleaving a
  growing number of smaller balance credits
• Hospital is forced to allocate staff to resolve
  the smaller credit balance accounts creating work
  pressure in PA
• Vendor credit balance auditors are paid by
  commercial insurers to recover overpayments but
  only 1/3 of the accounts are commercial, largest
  percentage of credit balance accounts are
  government and patients

33
Required Reporting of Medicare Overpayments CMS
838 Form

• Providers must submit Quarterly Reports detailing
  all Medicare overpayments
• CFO must sign the report attesting to the
  completeness and accuracy of the data
• Failure to comply may result in
• Financial penalties that include interest and
  fines/treble damages
• Criminal penalties
• Compliance is monitored as part of the cost
  report auditing process

34
COMPLIANCE SOLUTIONS

• To reduce risk and improve cash flow
• Processes established to ensure compliance with
  Medicare requirements for refunding credit
  balances and filing the CMS-838
• Determine total dollar amount and volume of
  credit balances
• Determine volume of new credit balances created
  on a weekly basis to determine risk

35
COMPLIANCE SOLUTIONS

• Determine thresholds allowed for credit balance
  levels based on total dollar and total volume of
  accounts (2 days of a hospitals revenue)
• Review current processes
• Automate manual processes
• Monitor unresolved Medicare credits
• Minimize fraud potential and issuance of refund
  checks by using payers processes and systems
  that allow reporting overpaid accounts insist
  on voucher recoveries by the payer

36
COMPLIANCE AREAS OF CONCERN

• Registration fraudulent use of identifications
  to obtain services / ID Theft by patients or even
  entity staff
• Insurance verification patient using another
  patients Medicare number
• Charge Capture overcharging / charging for
  services not provided, lost charges
• Billing Errors Duplicate billing
• Observation or IP Medicare and Medicaid
  correct status
• Charity Care evaluations for medical assistance
  eligibility

37
MEDICAID AUDITS STATE MEDICAID FRAUD CONTROL
UNITS (MFCU)

• For fiscal year 2006, from October 1, 2005 and
  ending September 30 2006, the MFCU received more
  than 1.1 billion in court ordered restitution,
  fines, civil settlements, and penalties. They
  also obtained 1,226 convictions in FY 2006.
• MFCUs reported 676 instances in which civil
  actions were taken with successful outcomes.
• Of 3,425 OIG exclusions from participation in
  Medicare and Medicaid programs, 731 exclusions
  were based on referrals made to OIG by the MFCUs.
• SOURCE State Medicaid Fraud Control Units Annual
  Report, Fiscal Year 2006

38
EXAMPLE IN TEXAS

• In Texas, a physical therapy clinic operator was
  sentenced to 51 months in prison and ordered to
  pay 1.32 million in restitution for conspiracy
  to commit wire fraud and health care fraud. She
  and her partner billed the Medicare and Medicaid
  programs for services not rendered and billed for
  physical therapy services as if they were
  performed or supervised by a licensed physician.
  The investigation revealed that the defendants
  hired unlicensed foreign medical graduates to
  perform the services of a licensed physician.
  The investigation involved OIG, the Texas MFCU,
  and the FBI.
• SOURCE OIG Semi-Annual Report for First Half of
  2007

39
KEY COMPLIANCE AND REVENUE CYCLE METRICS

• PATIENT ACCESS QUALITY
• Physician authorization compliance
• 96-98
• Inpatient admissions error ratio
• lt1-2
• Outpatient registration error ratio
• lt1-2
• Pre-registered IP accounts 40-50
• Pre-registered OP accounts 25-30
• HFMA Benchmarks

40
KEY COMPLIANCE AND REVENUE CYCLE METRICS

• CASE MANAGEMENT QUALITY
• Payer acceptance of clinical treatment plan based
  on authorization 95-97 acceptance
• Clinical denials overturn rate 95
• HFMA Benchmarks

41
KEY COMPLIANCE AND REVENUE CYCLE METRICS

• HEALTH INFORMATION MANAGEMENT QUALITY
• DNFB (discharged not final billed) and HIM bill
  holds
• Awaiting coding lt0.5 day in A/R
• Awaiting dictation lt0.5 day in A/R
• Charge capture quality 98 compliance
• HFMA Benchmarks

42
KEY COMPLIANCE AND REVENUE CYCLE METRICS

• PFS/PATIENT ACCOUNTING QUALITY
• Gross Days Receivable Outstanding
• lt 52 days outstanding
• A/R over 90 days 17-20
• A/R over 120 days 10-12
• A/R over 1 year lt 2
• Credit Balance A/R lt 1 A/R day
• Billing turnaround 5 days from DOS or discharge
• HFMA Benchmarks

43
KEY COMPLIANCE AND REVENUE CYCLE METRICS

• ALL REVENUE CYCLE DEPARTMENTS NET REVENUE
  EXPOSURE
• Denial overturn ratio 95-98
• Underpayments overturn ratio 95-98
• Bad debt expense as of gross revenue lt 2.5
• Bad debt expense as of net revenue lt 2-3
• HFMA Benchmarks

44
CHARGEMASTER UPDATES

• The CHARGEMASTER is a computer file that contains
  all the charges that a hospital makes. It is the
  link between services provided and the generation
  of claims and billings.
• Key elements to review in a hospital CHARGEMASTER
  are invalid or inaccurate CPT/HCPCS codes,
  invalid or inaccurate revenue center codes,
  inadequately defined procedures and tests,
  appropriateness of bundled CPT/HCPCS codes, and
  validity of service.

45
CHARGEMASTER UPDATES

• Must have an on-going CHARGEMASTER review since
  the factors that go into the CHARGEMASTER are
  constantly changing, including the annual updates
  of CPT/HCPCS codes, changes in reimbursement
  guidelines and advances in technology.
• SOURCE HFMA Compliance Checklist for Hospitals,
  Revised June 2002

46
NEW CMS CHANGES IMPACTING COMPLIANCE AND REVENUE

• PRESENT ON ADMISSION (POA) start date 10/1/2007
  is defined as present at the time the order for
  inpatient admission occurs conditions that
  develop during an outpatient encounter, including
  emergency department, observation, or outpatient
  surgery, are considered as present on admission.
  Purpose is to distinguish between pre-existing
  conditions and complications.
• All claims involving inpatient admissions to
  general acute care hospitals or other facilities
  that are subject to a law or regulation mandating
  collections of present on admission information
• POA indicator is assigned to principal and
  secondary diagnoses and the external cause of
  industry codes
• Issues related to inconsistent, missing,
  conflicting or unclear documentation must still
  be resolved by the provider.

47
POA AFFECTS PAYMENTS

• Starting 10/1/2007, CMS reduces payments in some
  cases when the patient acquires an infection (or
  other condition) during a hospital stay.
• Will not assign higher paying DRG to patients who
  have /suffer from the 8 conditions, unless they
  are documented as present on admission

48
EIGHT POAs NOT ASSIGNED TO HIGHER DRGs

• Serious preventable event object left in during
  surgery
• Serious preventable event air embolism
• Serious preventable event blood incompatibility
• Catheter associated urinary tract infections

49
EIGHT POAs (cont)

• Pressure ulcers (decubitus ulcers)
• Vascular catheter associated infection
• Surgical site infection mediastinitis after
  coronary artery bypass graft (CABG)
• Falls

50
POA (cont)

• MULTIDISCIPLINARY EFFORT
• HIM department / Coding professionals
• Finance
• Physicians
• Quality department
• Risk Management
• Compliance
• Support from Administration
• Vendor readiness

51
SEVERITY ADJUSTED DRGs

• CMS finalized the inpatient prospective payment
  system (IPPS) rule which forces hospitals to
  understand Medicares new approach to reporting
  complications and comorbidities (CCs) and
  determining what combination of primary and
  secondary diagnoses gets the most favorable
  reimbursement while remaining compliant

52
MS-DRGs

• The final rule has 745 Medicare Severity DRGs
  (MS-DRGs) that replace 538 existing DRGs.
• Severity adjusted DRGs are better designed to
  capture the extent of the patients illness and
  complications.
• There is a third category to describe the
  relative intensity of a patients illness.

53
MS-DRGs

• Before the final rule, there was simply the
  absence or presence of CCs. CMS has added a new
  category to describe the most severe secondary
  diagnoses major CCs (MCCs)
• The best reimbursement scenario will be unclear
  to a hospital in any given case when a patient
  presents with two or more diagnoses that meet the
  definition of principal diagnosis

54
MS-DRGs

• Hospital coders will be required to analyze
  sequencing to protect the hospitals bottom line
  because the principal diagnosis dictates the DRG
  and when there are two or more diagnoses that
  meet criteria for principal, Medicare allows
  hospitals to bill whichever it chooses.
• Hospitals must ensure both diagnoses were present
  on admission, drove the admission and were
  treated or evaluated.

55
MS-DRGs

• Compliance Officers should use case mix index
  (CMI) to monitor how well their hospitals are
  doing with documentation of changes.
• If the CMI flies above or below what it is now,
  consider why.
• Urban hospitals should expect CMI increases
  because they generally take care of sicker, more
  complex cases / that is what the severity
  adjusted DRG system is designed to recognize

56
MS-DRGs

• CMS states payments under the new DRG system are
  expected to rise in fiscal year 2008 by about
  3.5 when all provisions of the rule are taken
  into account, primarily as a result of the 3.3
  market basket increaseCMS
• Independent of Medicare reimbursement changes,
  the final IPPS rule has built-in payment
  reductions to account for what CMS considers to
  be the way hospitals adapt coding and
  documentation to capture severity of illness and
  thus get paid more under MS-DRGs and because CMS
  views the hospitals to be seeing sicker patients

57
MS-DRGs

• CMS has stated We do not believe there is
  anything inappropriate, unethical or otherwise
  wrong doing with hospitals taking full advantage
  of coding opportunities to maximize Medicare
  payment that is supported by documentation in the
  medical record

58
FUTURE FY08 IPPS FINAL RULE

• The FY08 Inpatient PPS final rule includes a full
  market basket (MB) update
• Increase of 3.3 effective October 1, 2007, for
  Inpatient PPS hospitals providing quality data
• MB 2.0 or 1.3 for those not submitting data

59
Impact of the Final Rules Changes

• The change in payment per case for hospitals in
  FY 2008 is estimated to average a 3.5 increase,
  estimated by modeling those changes shown in
  Table I Impact Analysis of Changes for FY 2008.
  

60
IMPACT ANALYSIS OF CHANGESTable I
Geographic Location Average FY07 Pmt Per Case in Dollars Average FY08 Pmt Per Case in Dollars Percent Change
Urban hospitals 9,304 9,663 3.9
Large urban areas 9,702 10,122 4.3
Other urban areas 8,826 9,110 3.2
Rural hospitals 6,993 7,081 1.2
61
Updates to Inpatient Rates

• The CMS impact analysis of the final rules
  changes attempts to account for
• The effects of the reclassification of diagnoses
  and procedures and the proposed recalibration of
  the DRG relative weights required by Section
  1886(d)(4)(C) of the Social Security Act
• Effects of changes in wage index values
• Effects of wage and recalibration budget
  neutrality factors

62
Changes to Inpatient PPS DRG Weights

• The final rule continues the 2-year transition to
  weighting DRGs on the basis of cost.
• For FY 2008 two thirds on cost one third on
  charges

63
Changes to DRGs

• The adopted Medicare severity adjusted DRGs
  (MS-DRGs)
• Are based on the current CMS DRGs
• Increase the number of DRGs from 538 to 745

64
Changes to DRGs

• MS-DRGs split some current DRGs based on
• MCCs major complications or comorbidities
• CCs complications or comorbidities
• No CCs

65
Changes to DRGs

• Factors in dividing DRGs
• Variance of charges of at least 3
• At least 5 of patients in the MS-DRG are falling
  within the CC or MCC subgroup
• At least 500 cases are in the CC or MCC subgroup
• There is at least a 20 difference in average
  charges between subgroups
• There is at least 4,000 difference in average
  charges between subgroups

66
Changes to DRGs

• Redistribute case mix
• Have a negative impact on rural hospitals, but
  CMS expects an offset to some degree from
  weighting on cost
• Necessitate (CMS says) an offset of 1.2 in FY08
  and 1.8 in FYs 2009 and 2010, for case mix
  improvement attributable to coding and
  documentation

67
Changes to DRGs

• MS-DRGs affect the Postacute Care Transfer Policy
• 273 of 745 MS-DRGs will be subject to the post
  acute care policy
• For qualifying stays, hospitals will be paid 50
  of the total inpatient PPS payment plus the
  average per diem for the first day of the stay
• Fifty percent of the per diem amount will be paid
  for each subsequent day of the stay, up to the
  full MS-DRG payment amount
• Includes MS-DRGs that share a base MS-DRG

68
Changes in the LTC-DRG Classifications

• The LTCH PPS updates to the LTC-DRGs
  (MS-LTC-DRGs) will be included with the IPPS and
  effective for discharges occurring on or after
  October 1, 2008 and through September 30, 2009

69
Outliers

• The fixed loss cost outlier threshold for FY08 is
  22,650 (down from the current 24,485)

70
New Services and Technologies Add-On Payments
(cont.)

• Add-on payments will not continue in FY08 for the
  new services and technology recognized in FY07

71
Recalled/No Cost/Partial Credit Devices

• The FY08 final rule expands the 2007 outpatient
  PPS final rule to pay a hospital less when a
  device is provided at no cost
• CMS will apply the policy when the hospital
  receives a credit equal to 50 or more of the
  cost of the device
• Hospitals will identify replacement devices CMS
  will reduce the DRG payment to reflect the
  hospitals lower cost

72
Hospital Acquired Conditions

• Section 501(c) of the DRA requires hospitals to
  begin reporting on October 1, 2007, at least two
  secondary diagnoses that are present on the
  admission (POA) of patients
• Beginning October 1, 2008, the two selected
  conditions will not be assigned to a higher
  paying DRG unless they were present on admission

73
Physician-Owned Facilities

• The rule includes provisions for more
  transparency by physician-owned facilities and
  their physician owners

74
FUTURE OPPS PROPOSAL FOR 2008

• Medicares 2008 OPPS rule updates the conversion
  factor by 3.3 but also forces entities to be
  more efficient by reducing the ability to bill
  for additional, individual services

75
2008 OPPS Proposed (cont)

• Other proposed provisions
• No separate payment for observation
• Ten outpatient quality of care measures
• ASC payment system revised
• Discounted device payments when manufacturer
  gives entity partial credit
• End to billing for consults

76
CONCLUSIONS

• REDUCING COMPLIANCE RISK and REVENUE CYCLE RISK
  will be more challenging and require increased
  system / entity policy audits
• INCREASING REVENUE will require more detailed
  documentation from all who are members of the
  REVENUE CYCLE and require more Access Services,
  Medical Management, CBO, Charge, Billing, Denial
  and process audits on a continuous basis
• MANAGING COMPLIANCE RISK surrounding the REVENUE
  CYCLE will require a willing MULTI-DISCIPLINARY
  TEAM with system and process improvement thinking
  who are not fearful of making changes

77
RESEARCH SOURCES

• HFMA www.hfma.org, Revenue Cycle file
• TWCC This Week in Corporate Compliance
• STATE MEDICAID FRAUD CONTROL UNITS ANNUAL REPORT
  FY 2006
• MEDICARE COMPLIANCE, VOL 16, NUMBER 32, SEPT. 10,
  2007
• APC PAYMENT INSIDER, VOL. 9, NO. 8, 8/07
• THIS WEEK FROM SG2 9/3/2007
• Also School of Hard Knocks