Few stand-alone or small network practices have the expertise to conduct the impartial coding, documentation, medical necessity and billing reviews expected as part of the OIG Final Compliance Plan. Although we can train members of your staff in auditing and training methods, experience shows us that physicians and extenders will learn best from experts in the field that have gained their confidence.

The deliverable is a plan that meets OIG guidance and focuses the physician practice on liability aversion and sound billing and financial practices.

Comprehensive Compliance Action Plan for Physician Practices

1. Preliminary Compliance Assessment:
The initial step in Compliance Planning is to meet with Practice Principals or Management to determine where the practice is in the process of Compliance planning. All efforts will be made to capitalize on existing staff, policy and procedure. After meeting to review current policies and processes, and determine the degree of compliance development desired, a report will be sent to Management detailing the recommended actions. The report may include all of the elements included in the Comprehensive Compliance Action Plan, or just those elements specified by the group.
2. Basic Plan Infrastructure
   a) Recommend Compliance Plan Structure and Components (Includes Manual)
   b) Compliance Committee Structure
   c) Develop Code of Conduct
   d) Implementation of Network/Practice Policies – Billing
   e) Review/Implementation of Practice Policies/Procedures- Human Resources
   f) HIPAA Assessment
3. Training, Education, Communication
   a) Employee Training – Compliance Plan
   b) Provider Training – Coding, documentation and billing
   c) Establish Reporting Mechanism
4. Auditing and Monitoring
   a) Billing Process Review – Report addresses ABNs, Credit balances, Claim Flow
   b) Billing Audit and Profiling
   c) Provider Chart Audit – E/M: Ten-chart review includes Network/Practice Summary report with individual provider section
   d) Network/Practice E/M profile with Comparative benchmarking
   e) Revenue Projections (Optional)
   f) Individual Physician/Provider education sessions to report review findings and give specific provider direction
5. Medical Necessity/Laboratory/Safety Audit
   a) Physician/Provider Chart Audit – Medical Necessity: As above, findings combined at Network/Practice, Provider levels.
   c) CLIA Policy and Procedure Review/Plan
   d) OSHA Policy and Procedure Review/Plan

All participants in the Comprehensive Compliance Action Plan for Physician Practices have the option of participating in the Compliance Maintenance plan (below). As specified in the initial compliance assessment, practices will receive whatever additional updates, trainings and reviews agreed upon as appropriate to the practice.

Physician Practice Compliance Maintenance Plan

Either following an initial Dacey Group education and audit product, or as an extension of the Comprehensive Compliance Action Plan for Physician Services, we offer an annual Practice Compliance Maintenance Plan.

This plan is designed to provide physician education, chart reviews for documentation compliance and correct coding at the CPT or ICD-9 levels. The focus of this product is to provide regular education and auditing updates to keep the practice both fine-tuned in these areas and current with the compliance environment.

This arrangement will provide external auditing and a track record of the efforts of the practice to meet compliance requirements. The complete plan includes the services listed below, but practices may choose to select only those services that address the specific needs of the practice.

The complete Compliance Maintenance Plan includes:

1. An annual review of the Practice Compliance Plan and plan updates
2. Two group provider education sessions per year
3. At least one annual 10-chart review per provider with individual meeting(s) (Note: Practices will receive and approve a review protocol that will delineate a phased approach to provider education/review. Providers not meeting practice standards may require additional education/review to meet practice standards. This addresses the response/discipline compliance plan element)
4. Summary report with individual provider section (per review)
5. Current/Historical E/M profiles with comparative benchmarking
6. Revenue Projections (Optional)
7. Off-site maintenance of profiles, compliance/coding ratings for benchmarking
8. Reviews include both CPT and ICD-10 code auditing
9. Twelve hours of question/answer research and response to coding or compliance related issues. This time includes report or practice memo generation. Issues may include but are not limited to: Provider-based status, incident-to, extender billing, electronic medical records etc.

*All provider audits are conducted prospectively (pre-billing), unless otherwise specified by the client. In the event of a retrospective review, all claims identified as being out of compliance with Federal standards should be refunded and refilled at the supported level of service.

**All charts, productivity and practice materials will be returned and are to be used solely for the purposes of this review. All materials are strictly confidential.

The objective of each physician program outlined below is to use the provider’s own work product to sharpen both coding and documentation skills. The programs for support staff are designed to facilitate these goals. All group provider lectures, seminars or direct education sessions are delivered personally by Bill Dacey, MHA/MBA, CPC, CPC-I

Direct provider education and custom programs are our specialty. Coding lectures, seminars or other presentations can be structured around many aspects of coding.

The Dacey Group Inc., is perhaps best known for direct education dealing with the basic or advanced E/M coding and documentation. All lectures incorporate compliance elements and a real-world approach to coding and billing.

Content can be directed towards outpatient, inpatient, teaching hospital or specialty-specific services or settings. Call or e-mail us and let us set up a program for you.

Physician Education Program* – Evaluation & Management Codes (E/M)

Sessions designed to give physicians a greater understanding of E/M for the office and hospital. Content focuses on how to translate the physician cognitive work product into CPT codes. Basic coding principles and associated documentation requirements are covered in lively, interactive sessions.

A brief review of the compliance environment, profiling, auditing and coding scenarios is included. The goal of this session is to promote correct coding. After 20 years of EM coding many physicians continue to under-code for their services and it the rare session where revenue opportunities are not identified.

For most non-surgical specialties in a fee-for-service environment the patient encounter is what you do, and your principal source of revenue. You need to recognize and report these correctly.

Refresh your understanding of what the EM levels are – and gain an intuitive recognition of each level that allows for easy and correct coding.

Physician Education Program* – Working with Others: Teaching Physicians, Incident-to and Split/Shared Collaborative Services

If you work with NPPs (Non-Physician Practitioners) you need to know the   requirements for direct billing under the MD NPI versus billing by the NPP.

Providers involved with residents in a teaching setting will learn what documentation and service requirements accompany working with residents.

Content focuses on attending or supervising physician documentation and coding and the role that can be played by physician extenders and residents.

The goal of this session is to clarify the ‘Incident-to’, Split/Shared and PATH requirements and bring a practical approach to coding and documentation. The latest Federal guidance and CMS commentaries are included.

ICD-10 for Physicians and Qualified Healthcare Professionals

Learn what the providers need to know about ICD-10 CM Diagnosis coding. The physician and NPP are the source of the codes, but in the age of EMRs, SNOMED codes and coding support tools there is a lot of bewildering information out there.

Learn what you need to know – and how to get there quickly.

The new system has many features that are unfamiliar, but they don’t have to be. The core concepts of ICD-10 are the same as ICD-9 and some common sense instruction can take some of the worry out of the transition.

This session covers ICD-10 format, basic content and guidelines – and we can tailor this to your specialty or group. As professional reimbursement moves towards risk-based and HCC style arrangements your diagnosis coding skills will need to be honed moving forward. Strengthen your core knowledge of this system.

Physician Education Program* – Compliance Plans for Physician Practices

Physicians will learn how the OIG Final Plan effects them, and what practical steps to take to reduce liability and audit exposure. Content focuses on the required elements of a plan – and how best to reduce audit exposure.

The goal of this session is to identify the specific measures a practice must undertake to be in compliance – and how simple this can be. Avoid negative audit activity and satisfy external regulatory requirements while simplifying policies and procedures.

Use the compliance process to identify coding opportunities – it will pay for itself and then some.

Office Manager & Billing Staff Program – How to Audit Physician Services

Office or hospital staff will learn how to set up internal monitoring mechanisms designed to avoid compliance pitfalls. What to look for in physician documentation pertaining to CPT levels of service and medical necessity.

Simple audit forms are provided. The goal of this session is to focus on areas of risk for physician billing and how to monitor this activity.

*All physician sessions include comparative profiling of specific physician specialties to national norms. Course materials include easy-to-read documentation guidelines.

Three Day Intensive Coding Course for Physicians

The Dacey Group Boot Camp – style Intensive training courses for physicians have led to AAPC coding certification for many physicians nation-wide, including over 100 providers in the largest practice in the United States.

Mr. Dacey has worked directly with physicians in the coding and documentation field for over 25 years and has a strong track record of success. Superior communication skills, hospital and physician practice management experience, and the ability to speak to physicians at their level sets this offering apart from any other commercially available product offering.

Whether your provider needs the coding basics, specific coding subject matter expertise, or desires certification – we can accomplish these objectives efficiently.

The three-day Physician Course is organized as follows:

Day One

• Introduction and Welcome
• Overview of the CPC Examination (as applicable)
• Review of Coding Fundamentals
• CPT Manual Overview
• E/M Section and Subsection Review
• E/M Service Level Selection (AMA criteria only)
• E/M Modifier Review
• Anesthesia Section Guidance
• Anesthesia Services Lecture

Day Two

Introduction to Surgery – Concepts and Conventions
Surgical Modifier Review

Detailed Review of Individual Surgical sections:

• Integumentary System
• Musculoskeletal System
• Cardiovascular and Respiratory System
• Gastrointestinal System
• Genitourinary System
• Nervous System/Eye and Ear

Day Three

In-Depth Review of Ancillary and Medicine Sections:

• Radiology Section
• Laboratory and Pathology Section
• Guidelines for Reporting for Panel Codes
• Medicine Section

HCPCS II Coding Fundamentals

Correctly Reporting Drug Dosages Using HCPCS Level II Codes

Diagnosis Coding (ICD-9-CM) Fundamentals

Diagnosis Coding and Reporting Examples for Outpatient & Professional Services

Studying for the CPC Exam

Guidelines for taking the CPC Exam

The sequence and timing as outlined above is designed to prepare your physicians for the AAPC coding certification exam in a condensed format. The three days of intensive instruction is delivered in a lecture-style format. Questions are handled throughout with strict adherence to course content.

Class will run from 8 AM sharp until 5:30 PM daily.

The course focuses on coding conventions and section-specific coding guidance designed to teach attendees code coding concepts. Homework may be assigned. Attendees will need to bring a current CPT Professional Edition (AMA Press), a current ICD-10 Book and a current HCPCS II manual (if available).

These courses can be held at your facility or at a local venue. We can arrange for an in-house exam to be proctored at your facility at a time of your choosing in some optimal proximity to the course.

Four-Day Intensive Coding Course

The Four-day Intensive Coding Course is organized the same as the physician course above – but includes more time on medical terminology, in-class exercises and coding and billing basics.

It is suggested that attendees have some basic Medical Terminology –we can teach you the coding.

The sequence and timing is designed to prepare you for the AAPC coding certification exam in a condensed format. The four days of intensive instruction is delivered in a lecture-style format. Questions are handled throughout with strict adherence to course content.

Class will run from 8 AM sharp until 5:30 PM daily.

These courses can be held at your facility or at a local venue. We can arrange for an in-house exam to be proctored at your facility at a time of your choosing in some optimal proximity to the course.