Policy Manual sample

MDT Home Health Care Agency, Inc. AGENCY COMPLIANCE PLAN The Compliance plan consists of four elements: Internal Audits, Internal Processes, External Audits, and External Oversight Internal Audits: Billing Audits- MDT Home Health Care Agency, Inc. Agency billing staff will perform 100% billing audits on each chart prior to billing the record. Medicare patient records will be billed as per Medicare guidelines. An initial RAP will be sent to the fiscal intermediary after the patient’s HHRG is derived from the initial SOC assessment. The final Medicare bill will be forwarded to the intermediary following the patient’s discharge from the agency. Bills for Medicare patients that are recertified every 60 days will be sent to the intermediary after the bill is audited. Private insurance cases will be billed according to the preferences of the payer. The billing review is retrospective. Bills that are in error will be adjusted after the billing audit. These audits ensure that the visits billed meet coverage criteria. Utilization Review – The UR audit is part of the Quality Improvement Program. This type of quarterly audit examines charts from a different perspective than a billing audit. This audit is concurrent as well as retrospective. The QI committee will review the results of these audits. The committee will discuss new procedures, policies, or educational programs that must be initiated to improve patient care and the documentation of the care provided. These audits ensure that our utilization of services is effective and appropriate, while meeting the needs of our patients and to helping the patient achieve the desired outcomes. Internal Processes: Computer Systems- Our internal billing system is integrated with the clinical system that processes and tracks MD orders, Nurses Notes, and Schedules. Bills are not processed unless that 485 and all orders are signed. This practice is in compliance with the Medicare Home Health Agency Manual. External Oversight-Medicare Certification Surveys-MDT Home Health Care Agency, Inc. will undergo a certification survey with State Surveyors. This will assure that the agency is following the Conditions of Participation required by the Medicare program. The agency will expect a survey every 1-3 years. Any changes will be made in accordance with the surveyors’ recommendations. An appropriate plan of correction will follow the survey if needed. The plan will then be completed in the appropriate time frame. External Audits: Compliance Audit- MDT Home Health Care Agency, Inc. will perform a 100% billing audit with each billing cycle. If a 20% or more error rate consistently occurs during the billing audits, an external audit will occur. We will then follow the recommendations of the compliance team and remedy all of the problems that caused the 20% error rate. Home Health Agency Policies A-137