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The ABC Compliance Program |
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In December 1998, the Office of Inspector General issued compliance
guidance for third-party billing companies emphasizing the importance of
billing companies establishing internal compliance programs. Then in
September of 2000, the OIG issued compliance guidance for physician
practices. |
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Anesthesia Business Consultants has worked with Wachler & Associates, P.C.,
a nationally recognized health care law firm with specific expertise in
anesthesia and pain management compliance, to implement a state-of-the-art
compliance program. ABC has also appointed a Vice President of Compliance
who serves as a hands-on compliance officer and the liaison between ABC
and the compliance officers of our clients. We have established the
infrastructure to operate a practical but effective compliance program
that benefits both ABC and our clients. And we believe that a key factor
in operating a successful compliance program is coordination with and
education outreach for ABC clients. |
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The ABC Compliance Program includes the following features: |
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An internal compliance department led by a full-time hands-on compliance
officer assisted by a staff of individuals including auditing and monitoring
personnel |
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A compliance library housing continually updated payor manuals for each state
served by ABC as well as other pertinent resource materials |
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A series of internal policies and procedures designed to increase compliance
and optimize efficiency |
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An internal auditing and monitoring department that actively monitors ABC's
internal compliance as well as client compliance |
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A compliance education program focusing on both internal continuing education
for ABC employees and education outreach for ABC clients |
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A specific chronic pain management expert and compliance liaison who works
with ABC coders, account managers and ABC clients |
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An internal reporting system for individuals to identify potential compliance
issues |
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In order to maintain an ongoing effective program, the ABC compliance officer
also regularly consults with the attorneys of Wachler & Associates, P.C. To
learn more about compliance and its application to physician practices, visit
the publications section of Wachler & Associates, P.C.
web site. |
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Contact us to learn more about the ABC
Compliance program |
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The Health Insurance Portability and Accountability Act (HIPAA)
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In 1996, Congress passed the Health Insurance Portability and Accountability
Act (HIPAA) to address multiple health care issues, including administrative
simplification. Of particular importance to ABC and its clients are the HIPAA
regulations governing: |
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Privacy of patient information |
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Security of patient information |
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Submission of electronic claims |
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The HIPAA regulations generally apply to all health plans, healthcare providers
who transmit any information in electronic form, and healthcare clearinghouses.
HIPAA refers to these groups as covered entities. |
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HIPAA Standards for Electronic Transactions
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Effective October 2002, claims submitted electronically to payors must be
submitted in the HIPAA standard format. HIPAA applies not only to Medicare
and Medicaid claims but also to commercial insurances, blue cross blue shield
plans and other payors. In general, all electronic claims for professional
services will have to be submitted in the ANSI ASC X12N 837 format or will be
rejected. |
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The HIPAA standard format contains certain required data elements not currently
carried on the traditional HCFA 1500 form including such elements as: |
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A payer responsibility sequence code (i.e., identifies the insurance carrier's
level of responsibility—primary, secondary, etc.) |
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A taxonomy/specialty code if the rendering provider is the same entity as
the billing provider |
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A greatly expanded section requiring a more specific designation of
relationships between the patient and the insured |
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ABC has been proactively monitoring the HIPAA standards for electronic
transactions for some time and is actively working on implementation of
system changes to ensure a smooth transition for ABC clients. ABC clients
can be assured that their electronic claims will be submitted in the required
HIPAA format by the compliance date. ABC clients can expect to receive
periodic updates and educational information regarding future information
that will need to be provided to ABC as part of the billing process. |
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HIPAA Privacy
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Effective April 2003, covered entities are required to be in compliance with
the HIPAA privacy regulations. This regulation governs the internal use and
external disclosure of protected health information ("PHI"). PHI includes not
only paper and electronic records but oral statements as well. The HIPAA
privacy regulations contain a number of requirements that will be imposed on
covered entities as well as a number of rights that must be afforded patients.
For example, in order for physicians to use or disclose PHI for treatment,
payment or health care operations, the physician must obtain the written
consent of the patient in a form meeting all of the HIPAA required elements.
Moreover, physicians are required to provide patients a HIPAA notice setting
forth the group's privacy practices in a form meeting all of the HIPAA
requirements. Physicians must also provide certain rights to patients such
as providing access to information. |
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Examples of steps that physicians should take prior to the compliance date
include: |
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Appointment of a privacy officer |
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Development of HIPAA consent, notice and authorization forms |
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Development of HIPAA privacy policies and procedures |
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Identification of HIPAA Business Associates |
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HIPAA privacy education for all staff |
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ABC also has certain responsibilities under the HIPAA privacy regulation as
both a Business Associate of ABC clients and a covered entity. ABC has been
actively monitoring the HIPAA privacy requirements and, although has always
viewed patient confidentiality as a top priority, is in the process of
evaluating its practices and taking measures to implement certain privacy
policies and procedures in conformance with HIPAA. |
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ABC also has the expertise to assist anesthesia and pain practices in their
HIPAA readiness and compliance. |
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Contact us if you are interested in
learning more about ABC's HIPAA services. |
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Web Site Legal Notice
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Privacy and legal information: When you visit our web site, we may
collect and store information about your visit, including the time and
length of your visit, the pages you look at, and the web site you visited
just before coming to ours. We may also record the name of your Internet
service provider. User questions, comments, and other feedback about this
web site are treated as non-confidential and may be used or disclosed without
notice or obligation to the user. There are opportunities on our site for you
to provide us with information about you and your interests, such as name,
address, telephone, or email address. We will not provide your information to
any other company. If you choose to share any personal information with us,
we may store it and use it for marketing research and other marketing
purposes. |
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Disclaimer of warranty and Internet site terms of use: The contents of
this Internet Site are the property of and copyrighted by Anesthesia Business
Consultants, LLC ("ABC"). Distribution, modification, reproduction, transmission,
publication, broadcasting, posting or other use of the contents without the
express written consent of ABC is prohibited. In no event shall ABC be liable
for any special, indirect, incidental or consequential damages of any kind
arising out of or in connection with the use of this Site. The materials on this
site are subject to change without notice. You may not post or transmit any
material that could constitute a violation of the United States Copyright Laws,
or which is unlawful, threatening, libelous, defamatory, obscene, pornographic
or profane material that could constitute or encourage conduct that would be
considered a criminal offense, give rise to civil liability, or otherwise violate
any law. Products, processes or technologies described on this Internet Site may
be the subject of other Intellectual Property rights reserved by ABC. Nothing on
this Internet Site shall be construed as conferring any license under any of ABC's
or any third party's intellectual property rights. Nothing on this Internet Site
shall be deemed a recommendation or inducement to use any information in violation
of any patent rights or copyrights. ABC believes that its links to publicly
accessible third party Web pages are legally permissible and consistent with the
common customary expectations of those who make use of the Internet. If an entity
does not wish that ABC link with their site, then ABC will remove the link from
this Internet Site upon their written request. You may provide links only to the
home page of this Site, provided (a) you do not remove or obscure, by framing or
otherwise, advertisements, the copyright notice, or other notices on this Site,
(b) you give ABC notice of such link by sending an e-mail to ABC and (c) you
discontinue providing links to this Site if notified by ABC. ABC reserves the
right to alter or amend any of the foregoing terms and conditions without
obligation or notice to users. Any such alterations or amendments will be posted
on our Site. Although the Site is accessible worldwide, not all products or services
discussed or referenced in the Site may be available in all geographic locations
or jurisdictions. ABC reserves the right to restrict the provision of any product
or service to any person, company, geographic area or jurisdiction it so desires,
in compliance with applicable law. |
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