Ensure Regular training for Billing and Coding staff

Don’t overlook continual training of your billing and coding staff. It’s a compliance principle that the OIG emphasized in its initial compliance guidance for laboratories in 1998 and it is still just as important today, particularly with changes such as ICD-10 on the horizon. One of the compliance officer’s roles, according to the OIG’s Compliance Program Guidance for Clinical Laboratories, is to develop and participate in a training program and ensure all appropriate personnel are knowledgeable about the compliance program and “pertinent Federal, State and private payer standards.” That guidance document says an effective compliance program depends on “regular, effective education and training programs for all affected employees.” So make sure you are training new staff and re-training existing staff on the laboratory’s compliance program, fraud and abuse laws, billing and coding requirements, and claims submission.

Specifically, with regard to billing and coding, the OIG guidance says “for certain employees involved in the billing and coding functions, periodic training in proper CPT/HCPCs and ICD-9 coding and documentation should be required.”

In a footnote the OIG emphasizes that coding responsibilities “create a greater organizational legal exposure, and therefore require specialized training” and advises laboratories to first fill coding positions with “individuals who have the appropriate educational background and training.” Once you hire appropriate staff, the guidance recommends in a separate footnote that at least annual training be provided for general compliance issues with increased number of annual training hours specifically for staff involved with coding and billing functions. It also emphasizes the need to train new staff as soon as possible.

When deciding what to highlight in training, look not just to new developments but also enforcement trends and issues the OIG highlights in its annual Work Plan, new guidance, fraud alerts and other guidance documents. And after you’ve trained and retrained staff, make sure the compliance message stuck—the OIG’s 1998 guidance says you should be auditing and monitoring your billing and coding compliance. Address any problem areas found in those audits with further training.

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