Category: Practice Management

Q: What differences did you see in your health growing up as a child in a chiropractic family?

A:  Neither I, nor my two sisters was ever vaccinated, something that was practically unheard of in the 1960’s.  Mom and Dad tell the story of finding a pediatrician who would falsify our paperwork so that it indicated that we had been vaccinated.  He even had to scratch our skin without inoculating us so that we would have the telltale signs of vaccination for the school authorities.  These measures wouldn’t have to be taken today, but it gives a good idea of the attitudes prevalent at the time.

I attribute the fact that I have never suffered from a serious illness, and can’t remember the last time I had a cold or the flu, to the fact that I was never vaccinated and my immune system was allowed to develop naturally.  When we were children, my sisters and I would bounce back from the occasional cold or flu long before the other kids.  While, from a parent’s point of view, having a healthy child is a great thing, having a chiropractic parent meant never being able to use the excuse, “I don’t feel good today,” to get out of going to school!  My parents tell the story of when I got the mumps as a toddler.  Dad woke up and adjusted my feverish body every hour on the hour all night long. By the next morning the mumps were completely gone!  That care plan certainly doesn’t match up with the three visits a week regimen that many chiropractors robotically prescribe today!

Q: What legacy would you like to leave personally and professionally?

A:  I’d like to leave behind a world better off for the contribution chiropractic makes to the health of individuals, communities, societies, nations, and the brotherhood of man.  A world in which children and adults aren’t indiscriminately drugged and where Senior Citizens experience a vibrant quality of life and abundant health until the day they lie down to their final rest.  A world in which it is accepted knowledge that health comes from within and not from outside the body.  A world where men and women respect their bodies and the world they live in, and recognize that the two are inseparably connected. A world in which chiropractic receives the rightful recognition it deserves!

Dr. Mark Sanna is the CEO of Breakthrough Coaching, LLC, a leading resource for personal coaching to chiropractic and multidisciplinary practices throughout the country.  He can be reached at Breakthrough Coaching, LLC, by calling 1-800-7-ADVICE.

In an effort to help you maximize all your services, Dr. Daniel Dahan has identified 7 departmental areas in your practice, which need to be addressed.  Each of these areas is being dealt with sequentially in The American Chiropractor.  By following the suggestions given, your office will not only maximize its potential, but also delineate areas of weakness that need your attention.

3. Billing Department

As is well known, the billing department has the most critical job in any one office.  Indeed, insurance companies, as well any third party payers, use highly computerized systems to analyze and sort through doctors’ claims.  Hence, the billing department must pay close attention to make sure that every detail on an HCFA 1500 form is not only accurate but appropriate.  Accuracy has to do with the code which best describes the service rendered.  Appropriateness deals with the usual and customary fee as well as repetitive use of any particular code.

The billing department should conduct continuous reviews/audit:

• Weekly: Auditing the accuracy of codes used.
• Monthly: General review of reimbursement for each code per service.
• Quarterly: Thorough in-depth look at how codes are being classified by payers and if there are any updates to implement.

The biller should be experienced and qualified.  It is highly recommended, as well, that he/she be certified.  One qualified biller is necessary for every $500k billed per year.

The doctor should meet with the biller weekly to get a complete analysis on any follow-ups made.  Changes should be posted daily and, typically, billed at the same time.  For the smaller offices (i.e.,< $8k per week) billing can be done 1-2 times per week to cut down on setup time.  The biller should have a current CPT codebook, a zip code driven fee analyzer, “code it right” manual and the ICD-9 book.

Even with the best treatments and remarkable office protocols, unless codes are billed properly, reimbursement will be very weak.

Dr. Daniel H. Dahan is the founder and CEO of Practice Perfect, one of the nation’s largest management and consulting firms for multidisciplinary centers.  For more information, call 866 67-DAHAN, (866) 673-2426 (Toll Free #), email [email protected] or visit www.dahan.com.

Much like the safety audits your office already performs, a walk-through can prevent violations before the Department of Health and Human Services’ Office for Civil Rights gets involved. Whether inspections are announced or executed without your staff’s knowledge, experts agree that they should be done at least annually for all departments and more often for high-risk areas. If you’ve found a problem area, then you want to do a walkthrough more often than once a year to get things really ironed out.

Though not mandated by the privacy rule, third party or anonymous reviewers are often an efficient, if costly, method of examining your facility’s HIPAA compliance program. The big thing is making sure that nobody knows what’s going to happen, because you want to see what people are doing on a day-to-day basis, not what they’re doing on their best behavior.

The types of violations often caught in walkthroughs range from simple mistakes—like leaving confidential faxes unattended or discussing Protected Health Information (PHI) in public areas—to trickier situations that may have been overlooked. Many times the problem is not a procedural violation, but an issue that hasn’t been thought through all the way.

Focus on Your Front Lines

Focus on areas with a significant amount of interaction with the public or patients. Waiting rooms, elevators and even fax machines are all areas where information can accidentally be heard or viewed by the public.

Example: In a recent walkthrough, I noticed that, though the office had obviously positioned computer monitors so that they could not be seen from the waiting room, staff members hadn’t considered the glass entryway to be an area of risk. As you walked in, you could look right over the employee’s shoulder.

Any time a privacy official is on the ground walking through, they should have their eyes and ears open.  However, experts agree that, while privacy officials should conduct informal walkthroughs frequently, there must be some method to document and track violations, and there must be follow-ups.

To solidify the process of monitoring HIPAA compliance, one consultant developed a walkthrough checklist. As a tangible record of violations, the checklist should be based on the privacy policies and procedures central to your organization. It can also include how many times the violation was observed. It gives you something to start tracking to see if you see any improvement or not.

The Next Step: Once the walkthrough has been performed and the violations logged, compliance officers and others can review the document to see what went wrong and where. The two main areas we look for are our training and the clarity of our policies.  If a violation is observed multiple times, you have to ascertain the causes behind it.

Some questions you should ask are:

1. Is our training missing the mark?
2. What could we do differently?
3. How can we better respond to complaints?
4. Are our policies unclear?

By pinning down answers to these questions, you can streamline your facility’s procedures and, thereby, avoid glaring HIPAA violations.

SET THE EXAMPLE

Tip: Remember to take HIPAA violations seriously, if and when they do occur. That means you’ll have to outline and impose sanctions according to the gravity of the violation. Not only does failure to apply penalties jeopardize your compliance program–it’s also against the law not to have a sanctions policy in place.

Following your sanctions policy will benefit you in the long run, as it proves to your employees the importance of maintaining privacy standards, while at the same time preventing them from using past inconsistencies to excuse or eliminate their responsibility to protect health information.

Word To The Wise: To correct the problems encountered during the walkthrough, experts concur that it is best left to the discretion of the privacy officer to determine how and when a sanction will be imposed. Usually, that officer complies with the overall HR sanctions policy; however, as the issues move in the direction of malicious and willful breaches of privacy, higher levels of sanctions—including termination—must be applied.

SAMPLE: The Walkthrough Checklist

Conduct a walkthrough to quickly and easily monitor your staff’s HIPAA compliance. This checklist, created by Patricia Johnston, a consultant with Texas Health Resources in Arlington, can help you catch violations and track problem areas.

 The Walkthrough Checklist  by Patricia Johnston, consultant with Texas Health Resourceds, Arlington

 

Activity	Observed		# of	Comments
	Y	N	Occurrences
Confidential information is discussed by staff in public areas.	___	___	__________	__________________
Conversations with patient/family regarding confidential information are held in public areas.	___	___	__________	__________________
Overhead and intercom announcements include confidential information.	___	___	__________	__________________
Phone conversations and dictation are in areas where confidential information can be overhead.	___	___	__________	__________________
Computer monitors are positioned to be observed by visitors in public areas.	___	___	__________	__________________
Unattended computers are not logged out or protected with password-enabled screen savers.	___	___	__________	__________________
Computer passwords are shared or posted for unauthorized access.	___	___	__________	__________________
Documents, films and other media with confidential patient information are not concealed from public view.	___	___	__________	__________________
Whiteboards in public areas have more than the allowable information.	___	___	__________	__________________
Medical records are not stored or filed in such a way as to avoid observation by passersby.	___	___	__________	__________________
Confidential patient information is called out in the waiting room.	___	___	__________	__________________
Confidential information is left on an unattended fax machine in unsecured areas.	___	___	__________	__________________
Confidential information in left on an unattended printer in unsecured areas.	___	___	__________	__________________
Confidential information is left on an unattended copier in unsecured areas.	___	___	__________	__________________
Confidential information is found in trash, recycle bins or unsecured pre-shredding receptacles.	___	___	__________	__________________
Patient lists, such as scheduled procedures, are readily visible by patients or visitors.	___	___	__________	__________________
Contractors, vendors and other non-patient visitor third parties are not appropriately identified.	___	___	__________	__________________
Staff are not wearing name badges.	___	___	__________	__________________
Patient records not filed in locking storage cabinets or rooms that are locked when unattended.	___	___	__________	__________________
Security access mechanisms for buildings or departments are bypassed.	___	___	__________	__________________
When questioned, staff demonstrate lack of privacy awareness.	___	___	__________	__________________

 

Dr. Eric S. Kaplan is CEO of Multidisciplinary Business Applications, Inc. (MBA), a comprehensive coaching firm with a successful, documented history of creating profitable multidisciplinary practices nationwide.  For more information, call (561) 626-3004.

Have you ever stopped to consider the importance of consistency?  Could consistency have an effect on profitability? Could having more consistency in day-to-day procedures save time?  Consistency is a key tool for success in any business.  Likewise, lack of consistency means confusion, and confusion is a challenge. Surveys show that people choose the places they do business based upon consistency. Customers or, in our case, patients like to be prepared for what they are going to do or to buy.  What would happen if you stopped in at your local fast food restaurant chain, and at that location, an arbitrary decision was made to only serve fish sandwiches, because the manager didn’t like red meat and French fries?  Would this cause confusion?  Would the staff member have to attempt to explain something she, herself, was confused about? Would you go back?  What would happen if you went into a grocery store and, each week, the food items were moved to different locations? Once again, confusion.

Consistency in your practice

People rely on and appreciate consistency to simplify their lives.  This concept definitely applies to a chiropractic practice.  Patients, as well as staff members, appreciate consistency in your office.  They are happier and more compliant when they know exactly what to expect while they are interacting with your practice.

Consistency in Staff

First and foremost is having a consistent staff.  Patients, once they are established, appreciate being greeted by a familiar friendly face when they walk in the door.  Regardless of the front desk assistant’s mood, health, or financial condition each day, each patient should be treated and greeted in the same friendly way.  Also, although it is virtually impossible not to have staff turnover from time to time, care should be taken during the hiring process in order to ensure that staff turnover will not occur often. Evaluate your applicants prior to hiring with regard to their past work patterns.  Look at whether they are consistent, or if they tend to “job-hop.”

Consistency in Office Visits

The actual office visit should also be consistent from visit to visit.  In other words, each time following the first visit that a patient is being treated in the office, he or she should know, within a reasonable degree of certainty, what to expect.  They should sign in the same way.  They should know where to go first, second, then third. For example, they should take a seat in the waiting room until it is time for them to be seen. How do they know this?  They are told what to do.  People will follow directions for the most part. Next, the patient should always be adjusted first.  This is a valuable aspect of consistency that a chiropractor can utilize right away.  If the patient always sees the doctor first, they can rely on that stability.  This avoids confusion among both patients and staff members.  All too often, the doctor will reverse the flow of therapy and adjustments in order to accommodate his or her own time constraints.  However, this will lead to your staff not knowing what you want to be done and when.  This will result in too many unnecessary questions!  “Doctor, what would you like me to do with Mr. Smith?”  The doctor will spend more time explaining than he will treating.  Most chiropractors never notice these flow problems because it is not their area of expertise.

Consistency in Care

The patient’s care plan must also be consistent.  All doctors should give their patients a detailed report of findings, and care recommendations that they should follow.  The care plan should be adhered to, not only in order keep your patient compliant, but also to keep the doctor in compliance.  Establish a standard of care, and stick with it.  Do re-evaluations, examinations, and therapy plan changes when they are scheduled. Always explain any changes to the patient and the staff so that everyone will be on the same page. Consistency reduces confusion, and will create more time.

Dr. Maurice A. Pisciottano, Executive Director of Pro-Solutions for Chiropractic, is a practicing chiropractor, noted lecturer, author, researcher and teacher.  He is well known for his practice management expertise and new patient development programs.  He has devoted the past 14 years to the development of the instrumentation and the computerization of chiropractic treatment and documentation.  Worldwide, Dr. Pisciottano has trained over 10,000 chiropractors and treated over 650,000 patients with the Pro-Adjuster^®.  He regularly lectures at Palmer College of Chiropractic in Davenport, IA, and at Logan College of Chiropractic in St. Louis, MO.  Dr. Pisciottano is an honors graduate from the Palmer College of Chiropractic.  He can be reached at Pro-Solutions for Chiropractic in Pittsburgh, PA, at 1-877-942-4284.

Q: I am interested in the field of occupational healthcare, but my approaches to industry have been unsuccessful in the past.  How can I break down the barrier I seem to be confronting?

A:  The treatment of most workplace injuries involves a “wait and see” approach, coupled with time off, bed rest, medication or surgery, and typically terminates in some degree of permanent disability.  This approach is unsuccessful and the statistics prove it.  There is little doubt that, if our occupational healthcare system is going to improve, the current strategy must change.  Chiropractic has a valuable role to play in revolutionizing the way the healthcare game is played.  However, chiropractors must learn to take an “inside-out” approach when offering their services to industry.  Many chiropractors make the assumption that industry speaks their language.  They make the fatal mistake of talking subluxation instead of prevention and rehabilitation.

Human Resource Directors are impressed with your ability to provide services such as DOT physicals, Drug Testing, Post-Offer Physicals, and Functional Capacity Evaluations—chiropractic adjustments are way down on the list!  Occupational healthcare services constitute valuable revenue centers for your chiropractic practice and, most importantly, they are the proverbial red carpet to treating workplace injuries.  Once you are on the inside—and have proven that you are a team player with the ability to significantly impact Workers’ Compensation costs—you have earned the opportunity to talk and deliver chiropractic.

Q: What is the most effective tip you can give regarding increasing collections in a practice?

A:  The most effective method for increasing your collections is to ask your patients for payment!  As Gandhi said, “If you don’t ask, you don’t get.”  Perceived value is an important concept to master when it comes to asking patients for payment.  Patients must perceive a value at or greater than what you charge for your service, or they will feel that your fee is out of line with the value they assign it.  It’s equally important for practice team members dealing with patient finances to have a high perceived-value for your services themselves. As the saying goes, you can’t sell what you don’t own!

In closing, remember, that person who asks the question controls the conversation.  Not only is it our duty to ask for and collect payments from patients, it is part of the healing process.  Patients who pay, stay, refer, and get better quicker!  Asking for anything increases the odds of getting it by 200%.  Once you master this skill—by exercising your asking muscle—often you’ll be surprised at how easy increasing collections can be!

Dr. Mark Sanna is the CEO of Breakthrough Coaching, LLC, a leading resource for personal coaching to chiropractic and multidisciplinary practices throughout the country.  He can be reached at Breakthrough Coaching, LLC, by calling 1-800-7-ADVICE.

In an effort to help you maximize all your services, Dr. Daniel Dahan has identified 7 departmental areas in your practice, which need to be addressed.  Each of these areas is being dealt with sequentially in The American Chiropractor.  By following the suggestions given, your office will not only maximize its potential, but also delineate areas of weakness that need your attention.

2. Treatment Protocol

Indeed, one of the most important aspects of a successful office is its treatment protocol (TP). Following are the advantages of having written treatment protocols:

1. Give your patient the best care available: Comprehensive note keeping will give each doctor a better understanding and, hence, the ability to give better treatment.  Rather than relying on memory, the doctor has thorough detailed notes and a plan of the proposed and recommended treatment.

2. By Organizing, you will maximize your patient flow: Too often, staff has no proper understanding of the doctor’s treatment or its necessity.  Thus, in any typical office, the staff and patients get frustrated which, obviously, results in poor management and poor retention.

3. Limit your liability: When TP is well and carefully established, a doctor can easily explain or even defend his or her position.  Detailed notes will show a carefully laid out treatment plan supported by objective treatment and medical necessity.

4. Enhance your billing/coding: By properly establishing TP, a good office manager/biller can easily identify possible errors and rectify them before sending out any forms. Even without having a medical background, a biller can easily determine proper coding by going over a well-structured TP.

5. Increase reimbursement: It goes without saying that insurance companies pay claims based on documentation provided by the doctor.  Using the proper TP is of utmost necessity given today’s sophisticated and automated billing systems, which allow for payers to thoroughly analyze any claim.

6. Decrease letter of medical necessity: As long as the doctor continues to treat patients day in and day out without paying attention to the complete TP, payers and their administrators will, understandably, demand letters of medical necessity explaining why such-and-such patient did not have a proper protocol as the regular established standard of medical/chiropractic care.

What to do to establish proper treatment protocol:
1. Take a seminar.
2. Review all forms used by your office and their usage.
3. Train staff on the reasons for establishing TP’S.
4. Regularly review all established TP’S and their procedures.

Dr. Daniel H. Dahan is the founder and CEO of Practice Perfect, one of the nation’s largest management and consulting firms for multidisciplinary centers.  For more information, call 866 67-DAHAN, (866) 673-2426 (Toll Free #), email [email protected] or visit www.dahan.com.

Q: What was it like growing up as a child of a chiropractor?

A:  Growing up, our toys were the equipment in Dad’s home office.  My sister and I would take turns climbing on to the headpiece of the old porcelain-based, high-low table and launching each other through the air by stepping on the spring-loaded foot piece.  There was always a plastic model spine around, which was very useful for frightening the neighborhood children during Halloween and for countless “show and tells” at school.  Since Dad was studying Applied Kinesiology, we learned it to.  We would amaze our little classmates by muscle testing them before and after they opened a package of sugar under their tongues.  My first patient was our family dog, who received so many “adjustments” from me that I think she expected an audible release every time I would pet her!  When asked, as a young child, what I wanted to be when I grew up, I would always answer, “a dog-o-practor!”

Growing up the child of a chiropractor had its challenges too.  I can remember the time when I was in the first grade and some kids called my Dad a “quack” during recess.  I remember being confused at first, and then hurt, that my Dad wasn’t as good as the other kids’ dads.  When I went home that night, my parents reassured me that Dad wasn’t a quack.  It was my first lesson in the discrimination that confronts chiropractors even today!

Q: What are your dreams & aspirations for the chiropractic profession?

A:  My goal is to see chiropractic recognized for its central and unique role in the delivery of healthcare.  My vision is to have all chiropractors experience the freedom that results from financial abundance.  I know that it is only by creating a generation of financially affluent chiropractors, who are motivated to support our profession, will chiropractic win the respect that it deserves.  It takes significant financial resources to affect public policy on a legislative level.  The best lobbyists and legal counsel are extremely expensive.  My goal can only be achieved if chiropractors come together in a spirit of unity to protect our profession.  Our chiropractic licenses are not an entitlement, they are a treasure.  A treasure that was hard fought for by a generation of chiropractic pioneers, some of whom were jailed for their convictions.  Many of us take for granted the ability to freely practice our profession, but we must remember there are still many who wish to deny us this right.  We can never stop fighting for the complete recognition of our value to humanity until the battle is won.  Our patients deserve nothing less from us.

Dr. Mark Sanna is the CEO of Breakthrough Coaching, LLC, a leading resource for personal coaching to chiropractic and multidisciplinary practices throughout the country.  He can be reached at Breakthrough Coaching, LLC, by calling 1-800-7-ADVICE.

Let’s face the facts.  Although the average chiropractor does see an occasional “walk-in” new patient, this is more the exception than the rule.  We, as chiropractors, consider that there is a minimum number of new patients that we need to see each week in order to be satisfied that our practice will continue to grow at the expected rate. The question, is what do we need to do to insure that new patients continue to arrive at our front door?

Every business should have a business expansion plan, as growth of a business normally occurs by acquiring new business.  Whether it is a new customer, new client, or new patient, new business is our lifeblood.  Wouldn’t it be helpful, in the case of a chiropractic practice, if that minimum number of new patients were planned for? The average practice would grow almost immediately. If you knew that there would be ten new patients in your clinic scheduled for next week, and you had your usual amount of “unplanned” new patients, your new patient worries would simply disappear.  By planning your new patient activities in advance, you are essentially guaranteeing yourself that, by doing activities this week, you will have new patients five weeks from now.

The first step in this process of planning for acquiring new patients is simply to make the decision that you are going to take control of this area of the practice.  Then, begin putting together your business expansion-planning calendar, a month-at-a-glance style calendar that goes at least a year into the future. The calendar should be on your desk where it can be looked at every single day. A list of all possible new patient procedures should be made.  This list has endless possibilities, but begins with the most straightforward activities—perhaps those that you do daily or weekly—like asking for referrals from your existing patients.  Pick Monday and Thursday next week for this process and write the activity in the calendar so that it is planned, and you know exactly when you will be doing this.  You will then want to plug this activity into your calendar for the next six months or so.  Do this same procedure with all of the activities you can think of that, realistically, you will accomplish, and insert them into your calendar well into the future.

Perhaps there is a health fair in your community every three months.  Make the necessary connections with the necessary people, and get those events scheduled into your calendar. Next, schedule your outside lectures for the next year. Schedule your staff training for each week. Perhaps once or twice per month, you need to get into your local business community and meet some key people.  Insert in your calendar that you need to do video consultations with your patients once per week.

These are only a few examples of new patient procedures; however, all too often, the doctor just “hopes for the best” by doing marketing procedures as needed or when he thinks of doing them or, worse yet, when that number of new patients is too low, and the stress levels begin to be too high.  If the activities are pre-planned, and written down, and the calendar gets looked at on a regular basis, the activities will be completed.

Once the calendar is complete, then the ball is essentially in your court.  You must look at the calendar, and do the pre-scheduled activities.  Once one is completed, make a large blue checkmark over that action so that it is clear that you did, in fact, do it. These actions can be adjusted within the calendar in order to make the most effective use of your time.  If you do not complete a scheduled task, and you realize it too late in that day to do it, then simply write in you calendar in red the words “not done.”  Then reschedule that activity as soon as possible and complete it.  As you view your month at-a-glance calendar, after the first few weeks, you will easily be able to tell if your business expansion planning is on track as you note all of the blue checkmarks, or way off the track if it is full of red ink words that say “not done.”

Get started on your calendar process as soon as possible, and watch the difference in your practice as well as the difference in yourself.  Once you have this system in place, and you are comfortable with your daily, weekly and monthly tasks being completed, you will have no trouble scheduling a little free time to relax and enjoy yourself.

Dr. Maurice A. Pisciottano, Executive Director of Pro-Solutions for Chiropractic, is a practicing chiropractor, noted lecturer, author, researcher and teacher.  He is well known for his practice management expertise and new patient development programs.  He has devoted the past 14 years to the development of the instrumentation and the computerization of chiropractic treatment and documentation.  Worldwide, Dr. Pisciottano has trained over 10,000 chiropractors and treated over 650,000 patients with the Pro-Adjuster®.  He regularly lectures at Palmer College of Chiropractic in Davenport, IA, and at Logan College of Chiropractic in St. Louis, MO.  Dr. Pisciottano is an honors graduate from the Palmer College of Chiropractic.  He can be reached at Pro-Solutions for Chiropractic in Pittsburgh, PA, at 1-877-942-4284.

Today, more than any time in our history, doctors are being watched.  Big Brother is watching!  So many offices are worried about HIPAA. Yes, if you violate HIPAA, you will receive a fine.  However, if you do not follow the rules of the OIG (Office of the Inspector General), you may not only be fined, you may face jail time.

As a consultant who works with integrated practices, it stuns me to see how many offices have integrated by themselves.  They get a legal document from a friend and move forward.  Then they wonder why they are on the cover of Dynamic Chiropractic.  There is no right way to do the wrong thing. Whether you are integrated or not, you must play by the same rules.  These are not separate for MD’s and DC’s; they, like HIPAA, are for all Healthcare.

If you are in practice, know the rules.  If you are integrated, hire an attorney.  While attorneys can help you with the legal documents, most often they are not familiar with billing, coding and compliance.  This is why consultants are so important—not just to provide you with the rules, but to make sure your practice is compliant.  It begins with knowing the rules.  

Code of Conduct

It is the policy of all of my clients’ offices to instruct and understand that all individuals associated with the practice conduct themselves in an ethical manner and in conformance with all federal and state laws and the policies and procedures of the employer. To this end, your office’s Conduct Code and Compliance Program are to be prepared to provide employees, as well as those with whom your office does business and the general public, with a formal statement of commitment to the rules of ethical conduct as spelled out in this Code.

It is imperative that all my clients and personnel comply with the standards contained in the Code, and immediately report any alleged violations thereof to the Compliance Officer.  This is where you begin.  You must designate an employee to hold this title and assist in investigating any allegations of wrongdoing. It is our policy to prevent the occurrence of unethical or unlawful behavior, to halt such behavior as soon as reasonably possible after its discovery, and to discipline personnel who violate the standards contained in the Code and the Compliance Program.

No Code of Conduct can cover all circumstances or anticipate every situation. Therefore, should an employee encounter a situation which is not addressed specifically by this Code, he/she should apply the overall philosophy and concepts of this Code to that particular situation, and observe the ethical standards of honorable people everywhere.

Ethics

It is the responsibility of your office to obey the law. Personnel are encouraged to report all that they are doing to achieve their goals, to record all transactions accurately in their books and records, and to be honest and forthcoming with auditors. We require that all employees conduct themselves in an honest and ethical manner, including honest bookkeeping, honest budget proposals, and honest economic evaluation of projects in all aspects of an employee’s work.

Conflict of Interest

Your office and all employees must avoid situations in which their personal interests could conflict, or reasonably appear to conflict, with the interests of their employer. A conflict of interest could exist in any opportunity for personal gain, apart from the normal compensation provided through employment or payment for services rendered.

Dealing with Suppliers and Patients

Conducting business with suppliers and referring providers may pose ethical or even legal problems. The following guidelines are intended to help all personnel to make the proper “ethical” decisions.

1.  “Kickbacks” and Rebates:  Employees (or their families) may not receive personal kickbacks or rebates in exchange for the purchase or sale of goods or services at any time.  “Kickbacks or rebates” can take many forms and are not limited to direct cash payments or credits. In general, if you or your family stands to gain personally through the transaction, it is prohibited. Such practices are not only unethical but are, in many cases, illegal.

2.  Gifts or Gratuities:  Employees may not, under any circumstances, accept gifts of money, nor may they solicit non-monetary gifts, gratuities, or any other personal benefit of any kind from suppliers or patients. Employees may accept unsolicited, non-monetary gifts from a firm or individual doing, or seeking to do, business with you only if the gift is of nominal value, or the gift is primarily of an advertising/promotional nature.

3.  Entertainment:  Personnel may not encourage or solicit entertainment from any individual with whom your office or employees do business. From time to time, employees may offer or accept entertainment, but only if the entertainment is reasonable, occurs infrequently, and does not involve lavish expenditures.

Overcharging

Insurers and patients shall not be charged for more expensive services or equipment than that actually provided. Examples of overcharging include:

· Billing for more complex or sophisticated (and thus more expensive) services or equipment than actually provided (up-coding);

· Billing two insurers, such as Medicare and a private insurer, for the same services or equipment; and

· Waiving a patient’s co-payment without informing the government so that the government believes that your charges are higher than they actually are.

Books and Records

Falsification of Records:  Federal law requires us to ensure that our books and records accurately reflect the true nature of the transactions represented.  It is against our policy for any employee to cause our books and records to be inaccurate.  This is why we like ink, versus pencil.

Examples of false or artificial record entries include the following:

· Making the records appear as though medical services or equipment were provided to a patient when, in fact, no such equipment or service was ever provided to that patient;

· Making the records appear as though one type of medical service or equipment was provided to a patient when, in fact, a different type of medical service or equipment was provided to the patient;

· Making the records appear as though a medical service or equipment was provided to one person when, in fact, it was provided to another;

· Making the records appear as though a medical service or equipment was provided to a patient on a certain date when, in fact, the service or equipment actually was provided on a later date; and

· The creation of any other records that do not reflect the true nature of the transaction.

Any employee who knows, or should know, that he or she is making false or artificial record entries shall be subject to disciplinary action, including possible termination.

Employee Relations

It is the responsibility of your office to provide equal employment opportunities to individuals who are qualified to perform job requirements, regardless of their race, color, sex, religion, national origin or age. There are laws that prohibit discrimination against minorities, sexual harassment, and similar misconduct. Regardless of any legal prohibition, every u employee has a right to work in an environment free of harassment or discrimination based upon sex, race, creed, physical condition or national origin. All employees shall treat each other with courtesy and fairness and have respect for the dignity of others.

Reports of Wrongdoing

Each employee has a duty to report any suspected violation of your office’s Code of Conduct. If any employee reasonably suspects that any employee, subcontractor or agent is involved in any sort of criminal wrongdoing, or has or is violating the guidelines or policies contained in the Code, that employee should immediately report those suspicions directly to the Compliance Officer. In the event that an employee feels that a report has been given inadequate attention by the Compliance Officer, the employee may report to the Clinic Owner or Administrator.

Remember this rule:  REPORTS OF VIOLATIONS BY EMPLOYEES MAY BE MADE WITHOUT FEAR OF RETALIATION.  This is a mandatory component.  If you would like more information, go online to Office of the Inspector General. 

And, finally, remember that compliance is not an option.  Follow your heart, be true to yourself, and be true to your profession.

The world of healthcare and compliance is based on results.

Dr. Eric S. Kaplan is CEO of Multidisciplinary Business Applications, Inc. (MBA), a comprehensive coaching firm with a successful, documented history of creating profitable multidisciplinary practices nationwide.  For more information, call (561) 626-3004.

Dr. Eric S. Kaplan NOTE:

Be sure to check the Upcoming Seminar Section for more information on a great chance to DO THE RIGHT THING!  For a limited time, register to win FREE tickets at www.lpgone.com, courtesy of LPG, our Title Sponsors.