E/M Coding Alert - 2012 Issue 9
Compliance: Your Staffers Will Be Less Likely to Whistle If You Follow These Tips
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Article Overview
This article covers practical compliance-program themes for healthcare organizations, with emphasis on internal reporting, staff communication, documentation, self-assessment, and response to concerns. It is aimed at administrators, coders, billers, compliance staff, and managers who want to understand general risk-reduction strategies discussed in the context of whistleblower exposure and federal oversight.
Why This Topic Matters
Whistleblower complaints can trigger significant legal, operational, and financial consequences. Understanding the broad compliance measures discussed here can help organizations evaluate whether their internal processes support early issue detection and appropriate response.
Article Sections
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Establish a compliance plan
Introduces the role of a formal compliance plan and references federal compliance guidance. The section focuses on the importance of having an active, organization-wide approach to compliance management.
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Set up an effective reporting mechanism
Discusses internal channels for employees to raise concerns and the importance of encouraging reporting. It also addresses manager behavior and organizational response to employee complaints.
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Take the next step
Covers follow-up actions after a concern is reported, including investigation, documentation, and internal communication. The section emphasizes tracking the handling of reported issues.
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Don't ignore outside reports
Notes that concerns may come from sources outside the workforce, including consultants and auditors. It also references the involvement of legal counsel in outside investigations.
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Raise awareness of your compliance plan
Focuses on educating personnel across the organization about the compliance plan and internal complaint process. It highlights the need for broad awareness among different staff groups.
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Interview departing employees
Addresses exit conversations with employees who are leaving the organization. The section frames departure interviews as a chance to gather useful information about operations and concerns.
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Assess yourself for risk
Describes self-evaluation of organizational exposure to higher-risk issues based on patterns, trends, and enforcement activity. It emphasizes looking at the organization’s own patient population and operating profile.
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Improve charting
Discusses strengthening documentation practices and using self-audits to find and correct problems. The section links charting quality with readiness for review and scrutiny.
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Use cross-education for clinical and financial departments
Highlights communication between clinical and business teams to reduce friction and improve understanding of shared goals. The section focuses on internal education across departments.
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Don't shoot the messenger
Addresses the risk of discouraging employees from bringing concerns forward. The section emphasizes the organizational response to staff who report issues.
What You Will Learn
- How compliance planning is framed as part of whistleblower risk management
- Why internal reporting channels matter in a healthcare organization
- What kinds of staff education and communication are emphasized
- How documentation and self-review are presented as part of compliance efforts
- Why organizations should pay attention to reports from both internal and external sources
Who Should Read This
- Healthcare administrators
- Compliance officers
- Coders
- Billers
- Practice managers
- Clinical supervisors
- Support staff
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