Recently, we told you about the importance of getting the right people to handle your coding and billing. But the work doesn’t stop once you’ve hired the best staff or outsourced with a reputable billing company. To keep on top of changes and compliance issues, training is essential. Here are answers to the classic five Ws: Who, What, When, Where, and Why, and the bonus, H: How?
Why? Compliance is key
Michael J. Sacopulos, JD, founder and president of Medical Risk Institute, says: “Coding and billing is the life blood of the practice, it’s the income.” So you need to make sure you get coding and billing accurate and stay abreast of all the requirements for compliant coding and billing.
That’s no easy challenge. “The landscape keeps changing,” notes Sacopulos. Medicare rules change annually, there are new codes annually and the OIG Work Plan—which highlights compliance concerns—changes annually, adds Karen Zupko, president of Karen Zupko & Associates, Inc. For example, “ICD-10 is a total game changer with [its] level of complexity,” notes Sacopulos. Zupko agrees, explaining that ICD-10 isn’t just about new codes but also “requires additional knowledge about anatomy and terminology.” Plus, with the burden of navigating different insurance carriers and benefits and qualifications, Sacopulos notes: “To think [coding and billing] is done accurately and professionally without lots of effort and training is just ridiculous.”
He emphasizes that there are two reasons why you need to focus on continual training for coding and billing staff:
- “It keeps them up to date because it’s a changing field.”
- “Just as important is the message it sends that this practice takes this topic very seriously and we are going to devote resources to it.”
As the OIG makes clear in its Compliance Program for physician practices: “It is in the practice’s best interest to ensure that individuals who are directly involved with billing, coding or other aspects of the Federal healthcare programs receive extensive education specific to that individual’s responsibilities.”
Who? Everyone
Sacopulos says that coding and billing are so integral to the practice that you shouldn’t just limit training to those charged with filling out the claim forms but include everyone in at least some level of training for coding and billing issues. “Let’s make sure everybody understands the big picture,” he says. Especially in smaller offices where staff is limited and people have to cover for each other when someone is out, he emphasizes “that’s all the more reason people have to be trained on this topic even if not tasked with billing and coding.” If the medical office has a billing company handle coding and billing, remember that entity is a legal agent of the medical office, says Sacopulos. “So the practice needs to make sure its coding and billing is being done properly because it is still legally on the hook for the coding/billing. This is impossible to do if the practice is not familiar with its current legal obligations,” he explains. Additionally, the practice is still part of the coding and billing process because it generates all the materials the billing company uses, adds Sacopulos, who warns “we cannot allow staff ignorance to hamper the billing company’s ability to do its job.”
When? Annually with periodic updates
The OIG says “there is no set formula” for when and how often you must provide training but it recommends at least annual training for staff involved with coding and billing functions. It emphasizes the ideal is to train new staff as soon as possible and have them work under supervision of an experienced coder until training is finished.
Where? Anywhere that makes sense for your office
Where you get the training will depend on what works best for your medical office needs and resources. In its compliance program guidance for physicians, OIG compliance program guidance for physician offices suggests a variety of training sources such as in-person seminars, community college certificate or associate degree programs, professional association continuing education and certificate programs, and insurance carriers as sources for training.
“The best training is through one’s specialty society because every page of content is likely vetted by their CPT coding committee,” advises Zupko. Ask your physician’s specialty society if they offer coding education, she suggests, because they often offer sponsored coding seminars, webinars and other training resources. Professional societies or coding organizations such as the AAPC or AHIMA often provide in-person seminars and conferences that keep attendees updated on the most current changes and provide networking opportunities as well. Send a physician with a couple of staff people for training, suggests Zupko, and you can use these trips as a reward for staff as well. In addition to the training, take them out to dinner or a show, she suggests, to add some fun to the venture.
If you have a small office, sending someone away to a conference for several days may not be feasible, she acknowledges. You don’t always have to travel or pay a lot of money to get reliable training. Professional societies and other organizations often offer publications that provide coding updates and guidance as well as webinars and other online resources. For example, you can earn an AAPC credential all online, she notes. Zupko also suggests you take advantage of any free training that government entities provide. For example, CMS provides resources on its “Outreach and Education” webpage and the Medicare Learning Network offers free webinars and other resources.
Finally, she notes that some medical offices provide in-house training either bringing in an outside provider or even holding lunches where a nurse or clinician provides information for the coding and billing staff. For example, with the increased need to know anatomy and clinical details for new ICD-10 codes, having your clinical providers educating billing staff on clinical issues can be helpful.
Caution: Make sure the training you select is reputable and right for your medical office’s needs and operations. Sacopulos advises medical offices to ask training providers for references. Check with those references and spend five minutes to find out what was beneficial. He also suggests looking at the credentials of the trainers and those who endorse those trainers — ask if they are certified coders and how much experience they have. Zupko advises you proceed with caution concerning commercial, industry-sponsored coding training. Sacopulos also cautions against relying on list serves and message boards for coding guidance noting potential HIPAA concerns, the risk of publicly disclosing incorrect billing or relying on inaccurate advice.
What? Start with the basics and tailor it to your practice
So what should your training encompass? Well, the OIG compliance guidance says there are certain risk areas in coding and billing that frequently get attention in audits and investigations. So, since the OIG is telling you these are common opportunities for trouble, it would be a good idea to include them in your training to ward off any problems. The OIG lists the following, among other items, as risk areas:
- modifier use,
- up coding,
- billing for non-covered services as if covered,
- and billing for items or services not rendered as claimed.
A good starting point is covering the risk areas the OIG has noted in that compliance guidance. Then also highlight issues the OIG has said are currently a concern. These are highlighted in the OIG Annual Work Plan and indicate where the OIG is seeing red flags, advises Sacopulos. Make sure those red flags are addressed in your organization. As we mentioned last month, Sacopulos observes that “shockingly few” medical offices make use of the guidance the OIG is giving in its Work Plan.
The OIG compliance guidance says you should also be auditing your coding compliance. So it’s a good idea to consider what those audits reveal as potential weaknesses for your medical office and address those issues with more training.
Finally, of course, it’s essential to make sure staff are updated on new developments. If your medical office is a specialty practice then also of course include specifics for that specialty. “Medicare requirements have gotten very specific,” notes Zupko. Just having a general AAPC coding credential may not be sufficient, she suggests, if your medical office includes a specialty such as orthopedics or behavioral health which “have their own nuances.” So get your coders trained on coding the specialty services that your office provides.
How? Use your budget as a guide but not a barrier to training
Remember how critical coding is to your bottom line when considering your budget for training. Training is an investment in your medical office’s financial and compliance success. While the sending staff to in-person seminars or conferences may be ideal, this may not always be possible for all medical offices. But don’t get too stingy with your training budget. “Saving money isn’t always saving money,” says Zupko. Some practices that are struggling are “struggling because no one knows what they are doing,” she explains. If there’s no investment in qualified staff, it becomes a self-fulfilling prophesy, she warns.
So if you can’t afford to send staff to an out-of-state conference every year, consider other ways to provide training. “Invest in external training every other year,” suggests Zupko. To keep your staff reasonably current in the “off years,” rely on industry publications or your specialty society’s publications such as articles and coding columns. “Use those columns as discussion to keep everybody up to date,” she advises. You can also consider webinars and online training and the free government resources we mentioned above. Sacopulos agrees. If you can’t send staff to seminars every year, consider online education where staff spend 45 minutes to an hour with the training and it’s easier to do at different times, he advises.
