Safe Harbor Group

Products And Services

• Auditing Services

  Your Trusted Partner For Billing & Coding Compliance Crucial elements of a practice’s compliance program include auditing and monitoring. There are many benefits to taking a closer look at your service lines. For instance, a comprehensive review of your organization’s coding and billing practices invites the opportunity to quickly identify and remedy any potential compliance issues. These steps should be taken so any scrutiny in the future can be easily handled. Additionally, a good audit can uncover unrealized coding opportunities and maximize revenue at the practice. What is a Billing & Coding Audit? A billing and coding audit is a comprehensive review of a medical service encounter compared to what was submitted for reimbursement to either a government or commercial insurance payor. This systematic review is conducted to ensure accuracy, compliance with Federal and state regulations, as well as coding guidelines to confirm appropriate reimbursement. It also provides an opportunity to readily identify compliance risks, catch any potential occurrences of fraud, waste, and abuse and make swift corrective actions. Audits are also chances for making improvements in clinical documentation; updating outdated Electronic Medical Record (EMR) systems; or conducting safer operational procedures. Did you know that while billing and coding audits should be performed at regular intervals as part of an entity’s compliance program, audits can also be performed for other objectives such as for due diligence in a potential merger or acquisition? It’s also important to conduct billing and coding audits when you employ a third-party billing company. Do not place your business at risk by skipping this crucial step. While it is good idea to perform your own routine internal audits, it is recommended you seek external assistance, get an objective partner who can conduct an analysis to better safeguard the practice from risk. Billing & Coding Audit Process The process of conducting a billing and coding audit is phased to ensure a complete look at the services provided. In general, an audit consists of a review of the following: Documentation Review Coding & Billing Accuracy Compliance Alignment Risk Mitigation and Education Justice Six Benefits of Routine Encounter Audits Conducting routine encounter audits are not only fulfilling a component of your compliance program, but they are also incredibly beneficial to healthcare providers for many reasons, including: Quality Assurance: Conducting audits confirms that documentation and coordinating billing and coding are compliant with regulatory standards Identified Areas of Improvement: Through the audit process, patterns or trends that indicate an opportunity for improvement can be identified Risk Management: Audits help address any potential legal or financial risk exposure for an organization. This proactive approach reduces any likelihood of regulatory scrutiny. Reimbursement Optimization: Thorough and accurate documentation provides maximum reimbursements and can reduce the amount of denied claims and potential requests for repayments. Collaboration: The audit process can provide opportunities for further education to occur for all staff members. The education process can fuel collaboration, sharing of insights and fostering a culture of learning and improvement within the practice. Enhanced Patient Care: Ultimately, by maintaining compliance, healthcare practitioners can focus on making more informed decisions and in turn, providing a higher standard of care for their patients.

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• Practice Compliance

  Understanding The Importance of Compliance in Healthcare In healthcare, maintaining compliance is not just advisable, it’s essential. Why does compliance hold such significance in medical practices? Healthcare compliance encompasses the continuous practice of adhering to legal, ethical, and professional standards in the clinical environment. It involves a spectrum of activities, regulations, and guidelines designed to protect patient welfare, safeguard data, ensure service quality, and uphold ethical conduct. What Does Compliance Mean in Healthcare? Compliance in healthcare means working within the boundaries of regulatory frameworks, adhering to an established code of ethics, and following professional guidelines. This realm is not limited to patient interactions but extends to every aspect of the business, from record-keeping and billing accuracy to employment practices and data security. As such, healthcare compliance is a comprehensive approach, ensuring that all activities within an organization are conducted in accordance with national and local regulations. Examples Of Healthcare Compliance The Role of Healthcare Compliance Organizations Corporate And Clinical Compliance in Healthcare Engaging A Healthcare Compliance Consultant Adapting To the Dynamic Nature Of Healthcare Compliance Programs The Seven Elements of An Effective Compliance Program The U.S. Department of Justice (DOJ) and the Federal Sentencing Guidelines for Organizations have set up criteria for what constitutes an effective compliance and ethics program. These guidelines form the backbone of compliance program requirements across various sectors, including healthcare, finance, and technology. Here are the seven foundational elements that the DOJ and Sentencing Guidelines show as crucial for an effective compliance program: Establishing Standards and Procedures to Prevent and Detect Criminal Conduct The cornerstone of any compliance program is the establishment of clear, written policies and procedures. These documents should outline internal standards for legal and ethical behavior, provide guidance on how to uphold these standards, and set up protocols to detect and prevent violations of law. They should be easily accessible, comprehensible, and implemented at every level of the organization. Oversight by High-Level Personnel Due Diligence in Delegating Substantial Discretionary Authority Effective Communication and Training on Compliance Standards Monitoring, Auditing, and Establishing Reporting Systems Consistent Enforcement and Discipline for Violations Responding to Offenses and Preventing Further Offenses

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• Compliance Programs

  Healthcare Compliance Programs Made For You As a healthcare organization, you are subject to numerous regulatory requirements and legal obligations. Failure to follow these requirements can lead to costly fines, legal action, and damage to your reputation. Therefore, it is essential for healthcare organizations to have a comprehensive compliance program in place to ensure compliance with all applicable laws and regulations. At Safe Harbor Group, we understand the complexities of healthcare compliance and can design a customized compliance program that meets the unique needs of your organization. Our team of compliance experts have considerable experience working with healthcare providers across the country to ensure compliance with federal and state regulations, including HIPAA, and fraud and abuse laws like the False Claims Act, Stark Law, and the Anti-Kickback Statutes. A Compliance Risk Assessment: The First Step in Tailoring Your Compliance Program To Meet Your Needs A comprehensive compliance program must include a risk assessment that finds the specific compliance risks faced by your organization. This assessment should take into account the unique characteristics of your organization, including the types of services you provide, your patient population, as well as your geographic location. At Safe Harbor Group, we have extensive experience conducting on-site risk assessments for healthcare providers. We will work closely with your organization to show and assess the specific compliance risks faced by your organization and develop a compliance program that addresses these risks. We Develop Custom Compliance Programs A comprehensive compliance program is the foundation of effective healthcare compliance. At Safe Harbor Group, we believe that every healthcare organization should have a formal compliance program in place that includes policies and procedures, training and education, internal monitoring and auditing, and be able to swiftly respond to identified issues. Our team will work with your organization to develop and implement a compliance program that is tailored to your unique needs. We take time to individualize your compliance program based on the specific risks and challenges faced by your organization. We will help you set up policies and procedures that outline the standards of conduct for your employees, ensure that all staff members are trained in these policies, and help you set up mechanisms to identify and address compliance issues before they become major problems.

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• Controlled Substance Compliance

  Controlled Substance Compliance in Healthcare Proper Controlled Substance Compliance is critical to avoiding regulatory penalties and maintaining patient safety. Our team provides guidance on prescribing practices, documentation, and inventory management to ensure full compliance with federal and state regulations. We help healthcare providers stay ahead of evolving laws while minimizing the risk of audits and enforcement actions. The Safe Harbor Group approach to controlled substance compliance Prescribing controlled substances is a key component of healthcare management for many types of healthcare providers, including family practice, pain management, and internal medicine. As these medications are prone to misuse and diversion, strict adherence to regulations for controlled substance prescribing is crucial. The Pillars of Controlled Substance Compliance To achieve controlled substance compliance, healthcare providers must focus on four key aspects: Controlled Substance Informed Consent Informed consent involves a transparent discussion between the healthcare provider and the patient regarding the prescribed medication’s potential risks, benefits, and responsibilities. For controlled substances, the informed consent process should cover the following: The purpose and expected benefits of the medication Possible side effects and risks, including the potential for addiction Safe use and storage guidelines, including proper disposal methods The importance of not sharing medications with others The provider’s monitoring plan, including regular follow-ups and periodic drug testing if necessary Potential consequences for non-compliance or misuse Providers should obtain written consent from patients, which should be kept in the patient’s medical record as documentation of this critical conversation. Controlled Substance Training DEA Controlled Substance Compliance Thorough Patient Evaluation and Documentation Partnering with Safe Harbor Group for Compliance Success SHG provides comprehensive compliance solutions to help providers navigate the complex world of controlled substance compliance. A partnership with Safe Harbor Group provides access to the following: Compliance Consultation: Our team can assess current prescribing practices and develop a customized compliance plan to address any areas of concern. Policy and Procedure Development: Controlled Substance Training: Audit Support: Controlled substance compliance is vital to ensure patient safety and avoid legal consequences. Safe Harbor Group is a valuable partner for providers seeking expert guidance and support in navigating the complex world of controlled substance compliance. Don’t leave controlled substance compliance to chance. Partner with SHG to develop a comprehensive compliance strategy that protects your patients and your practice. Contact us today to learn more about our services and get started on developing your controlled substance compliance plan.

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• Healthcare Defense

  Healthcare Fraud Allegations Navigating Healthcare Fraud Allegations Facing allegations of healthcare fraud can be a daunting and challenging experience. The potential consequences of a conviction under the healthcare fraud statute (1347), the False Claims Act, or the Anti-Kickback Statute can be severe and may include hefty fines, exclusion from government healthcare programs, and even imprisonment. Safe Harbor Group assists in the defense of healthcare fraud litigation and provide our clients with an edge in such cases. Investigation and Evidence Gathering Trial Preparation Federal Charges for Healthcare Fraud and False Claims Act Put Former Government Investigators to Work on Your Case

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• Statistical Sampling

  Statistical Sampling and Extrapolation in Healthcare: A Comprehensive Guide to Navigating OIG and MACs Audits Leveraging Expertise from Safe Harbor Group to Minimize Penalties and Overpayment Demands The Office of Inspector General (OIG) and Medicare Administrative Contractors (MACs) use statistical sampling and extrapolation to evaluate compliance and identify overpayments. Healthcare providers and organizations must be aware of these processes to protect their interests and ensure accurate billing practices. Here, we will delve into Chapter 8 of the Program Integrity Manual (PIM), detailing the conditions under which sampling and extrapolation are required. We will also outline the different phases of the process and explore how Safe Harbor Group can help you navigate these challenges, potentially lowering penalties and overpayment demands. Section 1: Chapter 8 of the Program Integrity Manual (PIM) The Centers for Medicare & Medicaid Services (CMS) have laid out the guidelines for sampling and extrapolation in Chapter 8 of the Program Integrity Manual (PIM). This chapter details the requirements for the OIG and MACs to apply these methods during audits, investigations, and other reviews. Sampling and Extrapolation Requirements According to Chapter 8 of the PIM, sampling and extrapolation may be employed when: The provider or supplier has a sustained or high level of payment error. The provider or supplier fails to respond to requests for documentation in a timely manner. There is an educational intervention by the MAC, which does not result in a significant reduction in the provider or supplier’s error rate. In these cases, the OIG and MACs can use statistical sampling and extrapolation to estimate overpayments and assess penalties. Section 2: Phases of Sampling and Extrapolation The process of sampling and extrapolation can be broken down into three primary phases: Phase 1: Selecting a Statistically Relevant Sample The first phase involves selecting a statistically relevant sample of claims or other data to analyze. The sample should be representative of the population under review and large enough to draw accurate conclusions. The OIG and MACs must ensure that the sample is random and unbiased, minimizing the potential for skewed results. Phase 2: Reviewing Files to Determine the Error Rate Phase 3: Properly Extrapolating the Findings Section 3: The Importance of a Private Sample If a healthcare provider or organization believes that the OIG or MACs have used improper sampling or extrapolation methods, they have the right to present their own sample as a rebuttal. This private sample must be conducted by qualified professionals, such as data scientists and medical record reviewers, who can accurately assess the documentation and calculate an error rate. By utilizing a private sample, providers can potentially demonstrate that the OIG or MACs’ findings are flawed or biased, potentially lowering penalties and overpayment demands. In some cases, the private sample may reveal a significantly lower error rate, which can have a substantial impact on the outcome of the audit or investigation. Section 4: Safe Harbor Group’s Role in Reducing Penalties and Overpayment Demands SHG offers a team of experienced data scientists and medical record reviewers who can help healthcare providers and organizations navigate the challenges of statistical sampling and extrapolation. By leveraging our expertise, you can ensure that your private sample is accurate, reliable, and compliant with the relevant guidelines. Sample Selection Our data scientists use sophisticated techniques to ensure that your private sample is random, unbiased, and statistically relevant. This ensures that the results accurately represent the larger population of claims or data. Medical Record Review Extrapolation Audit Support

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