Until more formal guidance is provided, the prudent healthcare entity will tailor its compliance program to meet its unique needs, using the seven elements set forth by USSC as minimum criteria. A common thread is incorporation of the of the facility or organization's code of ethics, which highlights minimally acceptable codes of conduct. Everyone along the chain - from the administrator who sets policy , to the physician who orders services, to the clerks who handle the order must know more about the process than just the task at hand. All work ends up in the form of a bill submitted for reimbursement. If payment is denied everyone who provides that service needs to know why , not just the billing manager.
Deterrence begins with identification of a problem.
Most staff, including managers, do not know how the facility is reimbursed for services that they provide, or know the criteria for that reimbursement. For example, a family wants the patient, at discharge, to go to the daughter s home 50 miles away. The ambulance is ordered by the physician at the family s request. Staff is unaware that the destination is out of the allowable mileage range. These and many other nuances create nightmares for the billing department.