Compliance Department

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.

1. Front Office/ Reception
2. Treatment Protocol
3. Billing Department
4. Collection Department
5. Marketing Department
6. Business Department
7. Compliance Department/Issues

The Process

The ultimate pursuit behind any healthcare office audit program is perfection in the clinical management.  A sound compliance management program enables the doctor to comply with the rules and regulations, which are aggressively pursued by the Office of Inspector General (OIG) when not adhered to properly.

A sound audit process serves to grade clinical management practices objectively, answering the basic question, “How are we doing?”  Even application of an error rate simply places a facility in a context weighted against its own perfection.  But the audit is also an opportunity to identify and correct errors.  Documentation, medical codes, billing and claims submission practices are all scrutinized and errors are addressed.  Over time, therefore, the monitored and regularly audited practice inches toward perfection.

The Elements

The most economical and safest way to develop an audit program is to address the most crucial list of 12 elements provided below.

1. Date of service
2. CPT code documented
3. CPT code billed
4. Modifiers documented
5. Modifiers billed
6. Diagnosis code documented
7. Diagnosis code billed
8. Diagnosis correctly assigned (item 24e)
9. Service units correct (item 24g)
10. Procedure report or note in record
11. Documented provider signature
12. Non-covered services billed

The Basic Setup

Basically, a set number of charts are pulled randomly on a monthly basis by a designated auditor.  The latter will want to pull all the HCFA-1500 forms, as well, which correspond to the sample charts.  Using a simply designed worksheet, all the above listed elements are carefully checked for accuracy.  After all items have been analyzed and mistakes noted (whenever applicable), totals are then recorded and tallied.  Typically, error rates higher than 20% are reason for concern, and immediate corrective action should be considered.  In such instances, it behooves the doctor to re-audit within 30 days to check whether training and corrective actions have proven effective.  If the error rate remains above 20%, practice owners and/or managers may want to consider hiring a consultant to review the audit results and make recommendations to quickly address this very important liability issue.  The goal, obviously, is to get the percent error rate as close to zero as possible.

Some possible reasons for high error rates:

• High turn over of employees
• Poorly trained staff
• Lack of attention
• Not understanding the serious consequences of mistakes being made

Each office is responsible for all the activities performed.  It takes a long time to a get a license.  It should be “safe” at all times.  Having a compliance management program is not an option; it is “the law”.

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

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