Developing Policies and Procedures John Behn, MPA Laurie Daigle, CPC

Objectives Understand the organization expectations Develop consistent practices and guidelines Establish reasons and benefits of P&Ps Understand the difference between policies and procedures Identify processes within your revenue cycle that can benefit from, or be improved by, policies and/or procedures

Facility Expectations Mission and culture Format Approval process Initial Changes Review requirements Understand facility or system expectations

Consistent Practices Research topic across departments System-wide Processes and expectations may vary slightly from department to department Should not contradict other policies or procedures Example Policy in billing may be that employees will be considered late if clocked in more than 10 minutes after scheduled Registration and call center may be three minutes after scheduled time Both policies should state employees are expected to adhere to scheduled hours within department Registration can stress the need to be available to patients

Considerations All policies and procedures must adhere to hospital system expectations HR Dress code Flex time Overtime requirements ADA Performance Other Compliance HIPAA Quality If necessary, confirm or clarify before rolling out

Reasons To Implement Policies Compliance Promote clear understanding of expectations Eliminate perceptions of favoritism Allow for consistent auditing or adherence Develop a consistent format

Format Policy and procedure should be expressed clearly and distinctly from one another Policy statement should be a few easy-to-understand sentences Expanded policy can introduce purpose, background Procedures should be broken into steps and should clearly outline expectations

Example procedure

Format Title Purpose Policy Procedure Title Policy: Procedure: Contact: Origination Date: Approved by: Signature: Pg.# File Name DEFINITION OF POLICY PURPOSE(S) OF POLICY: DEPARTMENTS AND MANUAL TO WHICH THIS POLICY APPLIES: DEFINITION OF TERMS: PROCEDURE(S): APPROVED BY: SIGNATURE: APPROVAL HISTORY: Page# File Name POLICY   TITLE: DEPARTMENT: PUBLISHED DATE: POLICY STATEMENT: PURPOSE: PROCEDURE: OWNER Department: Hospital Procedure: Responsible Unit: Status: Draft __________________________ Date of Procedure: Procedure Description:. Policy: Process:   Approved By:_____________ Date:_____________________

Example Dress Code Policy All employees are expected to wear clothing that is appropriate for their job and work site. Clothing and appearance should be neat, clean, and in good taste, and shall not constitute a safety hazard. Background XXXX interfaces with the public, and with professional vendors and organizations. As such, employees shall make reasonable efforts to project a professional public image. The following standards of dress code are established to provide direction for employees in order to maintain the professionalism that XXXX advocates. Procedure Employees shall practice good personal hygiene, and shall select attire that is clean and in good repair, and presents a professional image. Management may make exceptions for special occasions, and will work with Human Resources to determine whether attire is unprofessional on a case-by-case basis. Examples of professional attire include, but are not limited to: Business suits, blouses, shirts, skirts, pants, ties, dresses All shirts with collars, including casual shirts and blouses, golf and polo shirts Slacks and trousers Sports jackets Footwear designed for business purposes Appropriately fitted clothing for body type

Supplies Policy For all medical and surgical supply items, [Hospital] is establishing a policy to ensure all departments follow a specific set of guidelines to determine when a supply item should be charged to the patient (chargeable) and when a supply item should not be charged to the patient (non-chargeable). The criteria that establish a medical or surgical supply as chargeable are: The supply item should be a single use item in the provision of care to a patient, not in support of equipment or equipment maintenance The supply item should be considered disposable The supply item being utilized should have a “per unit cost threshold.” The per unit cost threshold is $5.00. Procedure: Any supply items that meet the policy criteria completely will be considered chargeable and will generate a charge to be included on the patient’s hospital bill. The supplier coordinator/manager will update the Charge Data Master and identify all billable supplies that meet criteria Set Billable flag to “Y” Apply a consistent 2X markup Exclude supplies from annual procedural markup process. EACH cost and the consistent markup will be the deciding factors on final supply charge. Create and append bar codes to each billable supply Perform periodic audits to validate costs Clinical staff must scan bar codes and ensure proper billing

Financial Assistance Policy  To remain viable as it fulfills its mission,  the hospital must meet its fiduciary  responsibility to appropriately bill and  collect for medical services provided to patients.  The hospital does not discriminate on the  basis of  race, color, national origin, age,  disability, sex, gender identify, religion,  reprisal and where applicable, political  beliefs, marital status, familial or parental   status, sexual orientation or protected  genetic information in its policies or  in its  application of policies, concerning the  acquisition and verification of financial  information, pre‐admission or pre‐ treatment deposits, payment plans,  deferred or rejected admissions, Low  Income Patient status as determined by (regulation XXX) Procedure 32 pages

Business Office Expectations Payor proficiency Account review Clearinghouse reviews and or claim Checks (internal edits) Who can request new edits Timeliness of rejection review Validation of 837, 835 files Cash posting Appeals A/R or ATB Work flow Backlog HIPAA

Coding Schedule and attendance Accuracy Production DNFB, deficiencies and late charges Auditing Audit expectation of coders Audit expectation for coders Work at home CEU, certification maintenance

Patient Access Schedule adherence Holiday, night, weekend hours Accurate capture of data elements Photo Demographics Insurance Medicare Secondary Payor MVA/WC Accident info Other Collections Copay, deductible, previous balances EMTALA Orders, authorization, medical necessity HIPAA

Thank You Stroudwater Revenue Cycle Solutions was established to help our clients navigate through uncertain times and financial stress. Increased denials, expanding regulatory guidelines and billing complexities have combined to challenge the financial footing of all providers. Our goal is to provide resources, advice and solutions that make sense and allow you to take action. We focus on foundational aspects which contribute to consistent gross revenue, facilitate representative net reimbursement and mitigate compliance concerns. Stroudwater Revenue Cycle Solutions helps our clients to build processes which ensure ownership and accountability within your revenue cycle while exceeding customer demands. Contact us to see how we can help. Laurie Daigle, CPC ldaigle@stroudwater.com 603-553-5303 John Behn, MPA jbehn@stroudwater.com 207-221-8277