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Department of Pathology, Immunology and Laboratory Medicine
BILLING COMPLIANCE PLAN
Reviewed October 2003
I. Billing Compliance Administrative Policies and Procedures
1.0 COMPLIANCE ASSURANCE
The Department of Pathology has a strong and abiding commitment to ensuring that its billing activities are conducted in accordance with applicable law. The Department recognizes the need to ensure that our physicians and staff are well informed about state and federal regulations applicable to billing, that we comply with these rules, and that performance is regularly audited so as to strengthen detected weaknesses. This plan is designed to assist in meeting these goals and provide guidance to the staff of the Department of Pathology.
2.0 REPORTING OF COMPLIANCE CONCERNS
The College of Medicine of the University of Florida is committed to providing an environment of honesty, integrity and trust. If you have concerns about legal or ethical issues speak with your departmental compliance officer or you may call the Office of Compliance Gator Hotline at 1-866-574-2867.
The Gator Compliance Hotline is a resource for all employees who may be confronted with ethical issues in areas such as Billing Issues, Proper Accounting and Record Keeping, and Relations with Government Officials and Regulatory Agencies
Anonymous reports are accepted. You may use this number to follow up or learn the results of the investigation process.
3.0 DEPARTMENTAL COMPLIANCE OFFICER
The Chairman of the Department shall appoint a Departmental Compliance Officer for the Department of Pathology. The Departmental Compliance Officer is responsible for actively participating in the COM Compliance Committee, working with the Office of Compliance personnel during the centralized audit process and working as a liaison between the Chair, Committee, Administrators, and the Office of Compliance to accomplish all the requirements of the Institutional Compliance Agreement. Such requirements include the screening for ineligible persons, regular centralized audits, and general and specific education of College of Medicine employees.
4.0 DEPARTMENTAL EDUCATION ACTIVITIES AND EDUCATION OF NEW EMPLOYEES
The educational activities and the education of new employees will be conducted in coordination with the Office of Compliance, so that such activities may be centrally documented and will meet the requirements of the Institutional Compliance Agreement. Additionally, compliance issues may be discussed on an ad hoc basis at department or divisional meetings.
5.0 REVIEW OF BILLING PRACTICES
5.1 Chart Monitoring
5.1.1 The Office of Compliance shall audit 12 encounters per Provider per audit cycle, in accordance with the Institutional Compliance Agreement.
5.1.2 The Departmental Compliance Officer will act as a contact person and facilitator within the Department. If requested, the Department will provide space for auditors to work and review documents during the audit process. The Departmental Compliance Officer or his or her designee will review audit outcomes prior to the circulation of audit findings.
5.2 Reporting
Once completed, the Office of Compliance will provide audit results to the Departmental Compliance Officer and the Department Chair. The Office of Compliance also shall maintain a database of audit outcomes.
5.3 Post-Audit Education
The Department is responsible for ensuring that any individual determined to require corrective educational action (as a result of the audit findings) attend educational sessions coordinated with the Office of Compliance.
5.4 Discipline
5.4.1 The Department Chair, pursuant to University rules and in consultation with the Office of Compliance, will be responsible for imposing the appropriate remedies and sanctions when compliance problems occur with Providers. The University’s existing remedial and disciplinary mechanisms for violations of billing compliance policies and procedures include but are not limited to letters of counseling, letters of reprimand, suspension without pay and termination.
5.4.2 A more detailed review of potential compliance violations and probable consequences can be found in a memorandum entitled “Billing Compliance Assurance Information.” This memorandum is available for review from the Office of Compliance web site at http://www.med.ufl.edu/complian/index.htm.
5.5 Expanded Audits and Refunds
5.5.1 There may be instances when the results of the audit process require that expanded auditing be conducted. The Department will be financially responsible for the costs of expanded auditing, which will be conducted by the Office of Compliance.
5.5.2 The Office of Compliance will identify overpayments, if any, arising from compliance audit activity (including regular and expanded audits), and track the timeliness of the refund processing by FGP Billing & Accounts Receivable Group in accordance with the provisions of the Institutional Compliance Agreement. The College of Medicine Director of Compliance, in consultation with General Counsel, will determine if any further action needs to be taken or if any disclosure needs to be made.
6.0 REVIEW AND UPDATE OF COMPLIANCE PLAN
This document, as well as other written policies and procedures for billing activities will be maintained by the Office of Compliance in coordination with the Department. The Department of Pathology Compliance Plan will be reviewed on an annual basis by the Departmental Compliance Officer and the Chairman of the Department in order to identify any needed modifications as well as specific compliance objectives during the succeeding year.
II. Billing Compliance Documentation Rules: Policy and Procedures
7.0 POLICY
7.1 It is the policy of the University of Florida and the College of Medicine that: (1) all claims for professional fee reimbursement use the proper code for the service provided; (2) the documentation in the medical record supports the billed code and physician presence/involvement; and (3) the claim is submitted in the name of the appropriate physician.
7.2 The term “Qualified Designee” will apply to a trained technical assistant, employed by the University of Florida, with designated faculty or trained technical assistant status.
7.3 All pathology reports will be reviewed and issued by the Teaching Physician. When appropriate, issuance of the report shall include the Teaching Physician’s electronic signature.
7.4 Teaching physicians are responsible for safeguarding the password to their electronic signature and ensuring that only the Teaching Physician may issue reports in his or her name.
7.5 All bills for pathology services will be generated as a consequence of the Teaching Physician performing the key portions of the pathology consultation.
7.6 Key portions of the procedure will be documented as follows:
7.6.1 Surgical pathology cases: Review of the gross description prepared by the resident, Qualified Designee or other faculty as well as all microscopic slides. All pathology reports should have one of the following affirmative statements:
A. All usual surgical pathology reports should have an affirmative statement: “I, or a Qualified Designee, have performed the gross examination and description and I have personally reviewed the gross description and specimen preparations referenced herein, and have personally issued this report.”
B. All pathology reports where the resident participated in grossing the specimen should have an affirmative statement such as: “I, or a Qualified Designee, have supervised the resident in the gross examination and description and I have personally reviewed the gross description and specimen preparations referenced herein, and have personally issued this report.”
C. For “consultation cases” for surgical pathology, and cytopathology where slides and accompanying reports are submitted for second opinion, transfer of patient or other reasons, the documentation of this review is by insertion of the following statement. “I have personally reviewed the accompanying paperwork, gross description and specimen preparations referenced herein, and have personally issued this report.”
7.6.2 Frozen sections: The Teaching Physician will be present at the time of all frozen section evaluation. He or she will review all slides and issue a signed report.
7.6.3 Gross only specimens: Examination of all "gross only" specimens by the Teaching Physician, or review of a description generated by the Pathologist’s Assistant, shall be documented by insertion of the following statement: "I, or a Pathologist’s Assistant, have performed the gross examination and I have personally reviewed the gross description and have personally issued this report."
7.6.4 Performance of Fine Needle Aspiration (FNA):
A. The Teaching Physician may accompany the resident and be present for the performance of the FNA procedure, or perform the FNA with the resident observing. In such a case, the following statement will be added to the fine needle aspiration biopsy report: “I have performed and/or supervised the resident in the performance of the fine needle aspiration biopsy, personally examined all microscopic slides and my diagnosis is as stated.”
B. In cases in which the patient’s attending physician supervises the pathology resident in FNA performance (and not the Teaching Physician), the patient’s attending physician will be the physician of record.
7.7 Clinical Pathology/Laboratory Medicine: The same general principles described above apply to reports issued by the Clinical Pathologist, including, but not limited to, interpretations of peripheral blood smears, electrophoreses, body fluids and microscopic examination.
7.7.1 Any preliminary interpretations performed and released for patient care use by the resident will be reviewed and interpreted by the Pathologist who will document this by an appropriate note such as: “The pathology resident initially prepared this consult. The consult was next reviewed by me and was edited and corrected by me as required to supply the correct interpretation of the laboratory data.”
7.7.2 For Hematology or coagulation related consultations “I have reviewed and interpreted the patient’s laboratory data.”
7.7.3 For Immune Panel consultations: “I have personally reviewed the flow cytometry cell patterns referenced herein and issue this report.”
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This page created 11/24/2003. Maintenanced 8/11/2004.
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