DEPARTMENT: Governmental Operations Support / POLICY DESCRIPTION: Continuing Education Requirements
PAGE:1 of 4 / REPLACES POLICY DATED: January 1, 2001
APPROVED: February 8, 2001 / RETIRED:
EFFECTIVE DATE: February 8, 2001 / REFERENCE NUMBER: GOS.GEN.007
SCOPE: All Company-affiliated facility and corporate personnel who work more than 160 hours per calendar year and the applicable Covered Contractors (who work more than 80 hours per calendar year), involved in the performance of billing and/or billing-related services (e.g., reviewing, editing, coding and/or filing of the final bill)for Federal healthcare programs at Company-affiliated facilities and Corporate Departments, Groups and Divisions, including but not limited to:
Business Office Director Billing Helpline Personnel
Laboratory Director Ambulatory Surgery Center Personnel
Outpatient Coders Corporate Health Information Management
Covered Contractors Physician Services Personnel
Facility Health Information Management Services Billers
PURPOSE: To ensure that all personnel involved in billing and/or billing-related services are aware of billing guidelines and regulatory changes, which may impact complete, accurate and consistent billing. The purpose of training shall include the following: (a) the submission of accurate bills for services rendered to Federal healthcare program beneficiaries; (b) policies, procedures and other requirements applicable to the documentation of medical records; (c) the personal obligation of each individual involved in the billing process to ensure that such billings are accurate; (d) applicable reimbursement statutes, regulations, and program requirements and directives; (e) the legal sanctions for improper billings; and (f) examples of proper and improper billing practices.
POLICY: Each person involved in the performance of billing and/or billing-related services must complete a minimum of eight (8) education hours per calendar year in billing and/or billing-related services. Only Company-designated programs may count towards this requirement.
Newly hired personnel involved in the performance of billing and/or billing-related services must complete a minimum of eight (8) education hours within the first 90 days of employment.
In any situation where training requirements have not been completed, a fully-trained HCA employee shall carefully monitor the work of the untrained person.
This policy does not replace other policies that address continuing education requirements specific to functional areas (such as the Coding Continuing Education Requirements Policy, HIM.COD.006 and the Coding Continuing Education Requirements for Company-Owned Physician Practices Policy, HIM.PHY.006).
DEFINITIONS:
Covered Contractor
A Covered Contractor is any agent or other individual (who is not a covered person) who prepares claims, cost reports, or other requests for reimbursement from any Federal health care program on behalf of HCA or any of its subsidiaries on a regular basis (i.e., for more than 80 hours within the calendar year).
Biller
A biller (inpatient or outpatient) is an individual who prepares, reviews, processes and/or submits claims to third party payers for reimbursement of medical services provided. These claims may be submitted on a HCFA 1450 (UB-92) or on a HCFA 1500.
The billing function includes the verification and correction of billing data for accuracy and completeness following regulatory requirements prior to submission. This function also includes resolving edits or exceptions detected during system processing of the claim. The act of submitting claims may be accomplished via electronic data transmission, mail and express mail and includes a timeliness factor.
Billing Training
Billing Training is defined as the training requirements defined in the Continuing Education Requirements Policy, GOS.GEN.007.
Outpatient Coder
An outpatient coder is defined as a person who performs the coding function for any outpatient treatment setting. The outpatient treatment setting is defined as outpatient visits and outpatient referrals in for laboratory, radiology, cardiology, cardiopulmonary and other diagnostic testing; laboratory testing performed on referred specimens only; observation services; emergency care; ambulatory surgery performed in either a freestanding or hospital-based ambulatory surgery center (ASC); provider-based programs, and physician office.
The coding function is the assignment of a numeric or an alphanumerical classification to identify diagnoses, procedures, and services (including medical visit). The outpatient coder reviews the source document (medical record) in order to assign these classifications or “codes.” The classifications utilized for this purpose include: ICD-9-CM (International Classification of Disease - 9th revision – Clinical Modification); CPT-4 (Current Procedural Terminology) or HCPCS Level II or III (HCFA Common Procedure Coding System).
In the event that an outpatient coder (defined as above) also performs the billing function (see definition of Biller), the individual is categorized as an Outpatient Coder for purposes of reporting.
PROCEDURE:
1.The facility Ethics and Compliance Officer (ECO) or Corporate Responsible Executive must designate an appropriate person to track the required education hours for each person involved in billing and/or billing-related services.
2.It is the responsibility of the designated person to ensure that each person performing billing and/or billing-related services receives the required eight (8) hours of billing education per calendar year.
3.Until the Company’s Learning Management system (LMS) is in operation at the facility, the designated person must use the tracking method located on the Company’s intranet at the Governmental Operations Support (GOS) site (which has been developed for the express purpose of interfacing with LMS).
4.The record of completed education hours (e.g., certificates of completion) must be a part of the permanent personnel file of each person performing billing and/or billing-related services.
5.The designated person will be responsible for reporting education hours on a quarterly basis by using the ECO Quarterly Report.
  1. Applicable Covered Contractors who perform the billing function must work with the facility and/or corporate office to receive applicable training.
7.It is the responsibility of the facility Ethics and Compliance Officer and relevant Corporate Responsible Executive to ensure appropriate processes are in place to ensure compliance with this policy.
8.The Corporate Government Programs Department will issue a certificate to each person who attends training covered by this policy that is supplied by GOS. The certificate will identify the number of hours applicable towards this policy’s continuing education requirement.
REFERENCES:
Coding Orientation and Training Policy, HIM.COD.005
Coding Continuing Education Requirements Policy, HIM.COD.006
Coding Orientation and Training for Company-Owned Physician Practices Policy, HIM.PHY.005
Coding Continuing Education Requirements for Company-Owned Physician Practices Policy,
HIM.PHY.006

2/2001