DEPARTMENT: Regulatory Compliance
Support
PAGE: 1 of 2
POLICY DESCRIPTION: Billing Monitoring
REPLACES POLICY DATED: 1/16/98, 3/1/99,
10/1/01 (GOS.GEN.001), 3/6/06, 9/1/07, 1/24/09
EFFECTIVE DATE: February 1, 2011
REFERENCE NUMBER: REGS.GEN.001
APPROVED BY: Ethics and Compliance Policy Committee
SCOPE: All Company-affiliated hospitals performing and/or billing services. Specifically, the
following departments:
Business Office
Admitting
Finance
Administration
Revenue Integrity
Nursing
Ancillary Services
Health Information Management
Utilization Management
Shared Services Centers
PURPOSE: To establish an effective monitoring process for Regulatory Compliance Support (REGS)
billing policies and procedures.
POLICY:
1. Each facility and/or services center must establish a monitoring process for reviewing compliance
with the Company's billing policies and procedures. Each billing policy and procedure should be
reviewed to define the payer scope of the monitoring activity. At a minimum, monitoring should be
performed for Medicare, Medicaid and other federally-funded payers.
2. The monitoring process will consist of two types of monitoring activities:
a. Automated Monitoring
Monitoring of facility claim level data will be performed at pre-determined frequencies by the
Regulatory Compliance Support department for the following billing policies:
REGS.LAB.002, Hematology Procedures
REGS.LAB.003, Urinalysis Procedures
REGS.LAB.004, Organ and Disease Panels
REGS.LAB.006, Outpatient Specimen Collection
REGS.BILL.006, Stat, Call Back, Stand-by and Handling Charges
The results of the automated monitoring activities will be disseminated to each hospital and/or
services center for review if exceptions to the above policies are identified. The hospital and/or
services center must review the results and confirm those identified as exceptions. If it is
confirmed that an overpayment has occurred, the account must be rebilled within 30 days of the
overpayment confirmation date. A corrective action plan may be required.
b. Hospital-Based Monitoring
Hospital-based self-monitors will also be performed to monitor billing compliance.
Each facility and/or service center must monitor each policy and procedure as specified in each
policy. The monitors must be completed within the timelines established by, and in accordance
12/2010
DEPARTMENT: Regulatory Compliance
Support
PAGE: 2 of 2
POLICY DESCRIPTION: Billing Monitoring
REPLACES POLICY DATED: 1/16/98, 3/1/99,
10/1/01 (GOS.GEN.001), 3/6/06, 9/1/07, 1/24/09
EFFECTIVE DATE: February 1, 2011
REFERENCE NUMBER: REGS.GEN.001
APPROVED BY: Ethics and Compliance Policy Committee
with, the monitoring instructions included with each policy.
3. The results of both monitoring activities must include review by an Oversight Group. The
Oversight Group can be a separate committee such as a “Facility Billing Compliance Committee”
or a sub-committee of the Facility Ethics and Compliance Committee.
4. This Oversight Group must consist, at a minimum, of the following individuals:
a. Chief Financial Officer;
b. Business Office Director and/or Patient Access Director;
c. Ancillary Department Director (e.g., Laboratory Director);
d. Health Information Management Director; and
e. Other individuals as deemed appropriate (e.g., Admitting Supervisor, Billing Supervisor,
Revenue Integrity personnel, Utilization Management personnel, Shared Services Center
personnel, , Physician Advisor).
5. The Oversight Group must meet routinely, and no less than quarterly, and will be responsible for:
a. Reviewing the results of the monitoring activities;
b. Maintaining documentation that describes the monitoring process, the results of the review, and
action taken as a result of the review. The documentation should contain, at a minimum, the
following elements: date testing performed with the monitoring tools, error rates, action taken,
status of action in place, dates of rebills, and corrective action plans;
c. Managing the monitoring process; and
d. Developing meeting minutes.
OTHER:
A listing of hospital and corporate based billing monitoring activities is located on Atlas at the
following link:
http://atlas2.medcity.net/portal/content/govprogs/opssupp/Frequency%20of%20Monitoring.doc.
The Facility Ethics and Compliance Committee is responsible for implementation of this policy within
the facility.
REFERENCES:
The Office of Inspector General’s Compliance Program Guidance For Clinical Laboratories (August
1998) pgs. 27-28
12/2010