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Summer 2006

Compliance Corner: 3 Cost-Effective Compliance Tips To Jump Start Your Compliance Efforts

Abby Pendleton
Wachler & Associates, P.C.

As part of our desire to keep both clients and readers up to date, the Communiqué has been printing compliance information since its inception. In the Compliance Corner, we will now formally keep you abreast of the various compliance issues and/or pick out a topic that would be of interest to most of our readers.


A vital component of any effective compliance program for an anesthesia or pain practice is to ensure that the practice is apprised of all major third party payor billing, coding and documentation policies and guidelines applicable to the services provided by the practice (i.e., anesthesia and pain services). The practice should be mindful that different payors often have different policies and thus compliance with one payor's policy does not necessarily equate to compliance with another's policy. In addition to being aware of all applicable policies, the practice must also understand these policies.

In order to make sure the practice is obtaining necessary billing and documentation rules and guidelines, the practice should designate an individual who is responsible for (1) determining which third party payors have published policies and guidelines (this can be accomplished by making telephone calls and researching websites); (2) creating a list of the payors (with applicable websites) that have policies and guidelines and keeping the list updated; and (3) obtaining the available information. The Medicare Carriers all have websites and many have email services that are easy to register with.


Once the practice is obtaining necessary billing and documentation information, the information must be appropriately disseminated to physicians. As the policies may contain requirements regarding documentation and frequency limitations in addition to coding issues, the physicians and providers in the practice should be included in the distribution. Many physicians believe that they do not need to review the materials as long as their billing company/administrative staff is aware of the policies. Physicians must understand that they are personally responsible for services billed under their numbers. Moreover, that the payor policies often contain information necessary for the physician such as specific documentation elements that must be contained in the record to support billing of a service. In addition to the potential audit and overpayment exposure that exists for failing to comply with payor policies and guidelines, physicians should be aware that certain patterns can lead to the physician being de-participated from a payor program.

In order to make sure that the practice has an effective distribution process in place, the practice should designate an individual responsible for (1) creating a distribution process and (2) ensuring that the process is carried out. The distribution process can be handled in a number of ways including having a person responsible for initially reviewing all materials and copying or highlighting pertinent portions to be distributed via email, mailboxes or in another manner. The person responsible may also consider creating a distribution spreadsheet that is marked off when materials are distributed. This will serve as a double-check to ensure that all individuals who need the information were provided the information.


As a compliment to TIPS 1 and 2, the practice should make compliance education a component in regularly scheduled Board or other corporate meetings. For example, when a new policy is published by Medicare that impacts the practice (e.g., a policy on anesthesia for endoscopy cases, etc.) , the policy should be discussed at the meeting to ensure that everyone has received the information and understands the information. If there are no new policies to discuss, the allotted time for education can be used to provide refresher education on other issues. For example, the definition of anesthesia time could be discussed to ensure everyone is tracking and documenting time appropriately. The practice should also document these educational efforts. This can be accomplished by drafting simple meeting minutes that reflect that compliance education on a particular topic took place. It is important to document that the education occurred. The documentation does not have to include all of the substance of the discussions.