Chief Compliance and Ethics Officer Health Care

Structure of Compliance Dept for Physician Practice

  • 1.  Structure of Compliance Dept for Physician Practice

    Posted 05-14-2020 03:48 PM

    Hello everyone –

    Our physician practice is trying to determine the right staffing size for its compliance department. Currently, compliance is a department of one with broad responsibilities for compliance, including revenue cycle. Our physician practice is a multi-specialty practice with 30 providers.  The revenue management/billing department was outsourced about 18 months ago.  Our HIPAA/Privacy compliance function is staffed separately.

    Could some of you provide information on how your compliance department/function is staffed for supporting your physician practice/clinics?  

    • How is compliance staffed?
    • Number of employees and FTE assigned to compliance:
      • Their primary responsibilities:
      • Certifications held:
    • How many employed providers (physician and APP) are in your practice?
    • Does compliance perform or outsource routine annual coding and documentation audits?
      • Number per provider/year:
    • Does compliance perform or outsource problem-focused billing audits?
      • Number per year:
    • Does compliance provide new provider orientation?
    • Where does compliance fit on your organization's org chart?
    • Any other staffing or responsibilities info you'd like to share?
    I appreciate your time.

    Eliza

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    Eliza Bardin
    Assistant Director, Compliance
    UCF College of Medicine
    Orlando, FL
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    2020 HCCA Compliance Institute


  • 2.  RE: Structure of Compliance Dept for Physician Practice

    Posted 05-15-2020 06:04 AM

    How much work is there with 30 physicians? To me that's the real question. You need to take a look at what's in place in terms of infrastructure (I.e do you have adequate policies / procedures), what are your risk areas (I.e, how much work will we have because we need to do X, y and z) and what is your intake (I.e, do you get a lot of reports and  requests for help). Once you've analyzed these factors you can make a business case for your staffing - probably somewhere in the range of 1-3 people I'd guess with possibly combining privacy into one of those positions. 


    As for staffing, certifications don't impress me. It's easy to pass a test and not know anything. 



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    Brenda Manning J.D., C.H.C., C.H.P.C.
    Privacy Director
    Interim Privacy Officer
    Carilion Clinic

    The views expressed herein are my own and do not represent those of my employer. They are not meant to constitute legal advice or create an attorney-client relationship.
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    2020 HCCA Compliance Institute


  • 3.  RE: Structure of Compliance Dept for Physician Practice

    Posted 05-15-2020 11:28 AM
    Thanks, Brenda. You make great points about needing to look at infrastructure, risk areas and intake.

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    Eliza Bardin
    Assistant Director, Compliance
    UCF College of Medicine
    Orlando, FL
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    2020 HCCA Compliance Institute