DEPARTMENT: Regulatory Compliance Support / POLICY DESCRIPTION: Billing Continuing Education Requirements
PAGE: 1 of 7 / REPLACES POLICY DATED: 2/8/01, 1/1/02, 5/1/02, 9/1/02, 5/15/03, 1/1/04, 4/15/04, 11/30/04, 1/1/06 (GOS.GEN.007)
EFFECTIVE DATE: March 6, 2006 / REFERENCE NUMBER: REGS.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 Manager/Director Regs Helpline Personnel
Billing Manager/Director Outpatient Coders
Laboratory Director Corporate HIM/Coding Compliance Facility Health Information Management Billers Physicians Employed Directly by the Hospital Covered Contractors
Emergency Department Personnel Hospital-based Clinic Personnel
Owned Freestanding Outpatient Centers Personnel (e.g., ASC, ImagingCenter, RadiationOncologyCenter)
PURPOSE: To ensure that all personnel involved in billing and/or billing-related services for Federal healthcare programs 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:
  1. Each person involved in the performance of billing and/or billing-related services for Federal healthcare programs as well as the Business Office Manager/Director and the Laboratory Director 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.
  1. Newly hired personnel involved in the performance of billing and/or billing-related services for Federal healthcare programs must complete a minimum of eight (8) education hours within the first 90 calendar days of employment. The work of newly hired personnel (within the first 90 calendar days of employment) must be carefully monitored by a fully-trained HCA employee until the training requirements have been met.
  1. In addition to the minimum 8 hours of education described in # 1 above, newly hired and existing personnel who have been designated in the HLC as Medicare billers, Business Office Managers/Directors, Billing Managers/Directors, OP Coders or IP/OP Coders must also meet the education requirements defined by the CIA Medicare Outpatient PPS (OPPS) Workplan within the prescribed timeframes. The education hours associated with the CIA Medicare OPPS Workplan may exceed the minimum 8 hours education.
All mandatory education requirements defined by the CIA, the CIA Medicare OPPS Workplan and Regulatory Compliance Supportare included in the "Training Requirements" documents for the appropriate calendar year. These documents are located on ATLAS using the following link:
If the mandatory courses listed on the"Training Requirements" documents for a specific CIA related job function does not equal at least 8 hours, the employee is responsible for completing additional Regulatory Compliance Support education hours until the 8 hours is met. In no case should the education hours fall below the 8 hour minimum requirement defined by the CIA.
  1. This policy does not replace other policies that address continuing education requirements specific to functional areas (such as the Coding Continuing Education Requirements Policy, REGS.COD.006, and the Coding Continuing Education Requirements for Outpatient Services Group Entities REGS.OSG.006).
  1. Individuals not defined in 1-3 above must receive, review and implement instructions included in billing education and/or billing-related communication as it relates to their job responsibilities (e.g., Case Managers, Revenue Integrity Management and staff, relevant Ancillary Department Managers and staff, and ED staff).
DEFINITIONS:
Federal healthcare program: Any plan or program that provides health benefits, whether directly, through insurance, or otherwise, which is funded directly, in whole or in part, by the United States Government (other than the health insurance program under chapter 89 of title 5 of the United States Code — the Federal Employees Health Benefit Program); or any State health care program, as defined in 42 U.S.C 1320a-7(h).
Federal healthcare programs include, at a minimum, the following:
  • Medicare Program, Parts A & B (Title XVIII of the Social Security Act); (but not Medicare managed care plans)
  • Medicaid (Title XIX of the Social Security Act); (but not Medicaid managed care plans)
  • Federal Prison Hospitals (prisoners);
  • Indian Health Service;
  • OWCP (workers' compensation for federal employees);
  • Public Health Service;
  • Railroad Retirement Board;
  • The Black Lung Program;
  • TRICARE/CHAMPUS/Department of Defense healthcare programs (Chapter 55 of Title 10, United States Code); and
  • Veterans Administration (VA).

CIA:Corporate Integrity Agreement, effective January 2001

CIA Medicare Outpatient Prospective Payment System Workplan: A workplan associated with the CIA, effective January 2001
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, updates and/or submits claims to third party payers for reimbursement of medical services provided. The billing function includes the verification and correction of billing data for accuracy and completeness following regulatory requirements prior to claim submission. This function also includes resolving edits or exceptions detected during system processing of the claim. These claims may be submitted on a CMS 1450 (UB-92) or on a CMS 1500.
The definition of biller also includes any employee’s immediate supervisor who supervises the preparation, review, updating and/or submission of claims to a third party payer for reimbursement of medical services provided.
(Only billers who bill Federal healthcare programs must be tracked in the Company’s HealthStream Learning Center (HLC).
Example:
If an employee is making changes/editing directly into EP Billing Vendors, Common Working File (CWF), Fiscal Intermediary Shared System (FISS) or Medicaid on-line systems or if the employee changes or signs a manual claim, this employee is considered a biller.
If an employee is reviewing the medical record and making recommendations to the biller and not making changes/editing directly into EP Billing Vendors, CWF, FISS or Medicaid on-line systems, this employee is not considered a biller.
Employees who only make changes to the CDM or only enter charges through Meditech are not considered billers.
Billing Training: Billing Training is defined as the training requirements defined in the Continuing Education Requirements Policy, REGS.GEN.007.

Business Office Manager/Director or ServiceCenter Billing Manager/Director: A Business Office Manager/Director is defined as a person who supervises individuals meeting the definition of “biller.” This designation is made based on the individual’s job function, regardless of title, i.e., this individual may or may not have the title Business Office Manager/Director.

Freestanding Imaging Billing Personnel are defined as FreestandingImagingCenter employees who prepare, review, update and/or submit claims to third party payers for reimbursement of medical services provided. The billing function includes the verification and correction of billing data for accuracy and completeness following regulatory requirements prior to claim submission. This function may also include resolving edits or exceptions detected during system processing of the claim. These claims may be submitted on a CMS-1500.
This definition also includes any employee’s immediate supervisor who supervises the preparation, review, updating and/or submission of claims to a third party payer for reimbursement of medical services provided.
FreestandingImagingCenter employees, who review medical records, determine the appropriate use of modifiers, and assign modifiers are also considered Freestanding Imaging Billing Personnel and must meet the education requirements.
Inpatient/Outpatient Coder: Refer to Company policy REGS.COD.006 for the definition of an inpatient/outpatient coder.
Other Billing Personnel: Other Billing Personnel are employees who are not considered billers according to the above definition, but must meet the biller education requirements as outlined in this policy. These are employees who review the medical record, determine the appropriate use of modifiers and apply the modifier directly into the patient accounting system(s).
Employees who do not enter modifiers directly into the patient accounting system(s) are not required to meet the education requirements outlined herein.
Outpatient Coder: Refer to Company policy REGS.COD.006 for the definition of outpatient coder. In the event that an outpatient coder (as defined in REGS.COD.006) also performs the billing function (see definition of Biller); the individual is categorized as an Outpatient Coder for purposes of reporting.

Physicians Employed Directly by the Hospital: Those physicians who are employed full-time directly by the hospital and who are involved in the ordering, performing or monitoring of laboratory tests or services or the preparation of outpatient claims containing laboratory tests or services.

Employed physicians who meet the definition of biller are required to complete the educational requirements outlined in this policy. Employed physicians who do not meet the definition of biller are required to complete the education requirements as outlined in the Company’s Laboratory Compliance Plan. The Laboratory Compliance Plan may be accessed via Atlas at:
Radiation Oncology Billing Personnel are defined as RadiationOncologyCenter employees who prepare, review, update and/or submit claims to third party payers for reimbursement of medical services provided. The billing function includes the verification and correction of billing data for accuracy and completeness following regulatory requirements prior to claim submission. This function may also include resolving edits or exceptions detected during system processing of the claim. These claims may be submitted on a CMS-1500.
This definition also includes any employee’s immediate supervisor who supervises the preparation, review, updating and/or submission of claims to a third party payer for reimbursement of medical services provided.
RadiationOncologyCenter employees, who review medical records, determine the appropriate use of modifiers, and assign modifiers are also considered Radiation Oncology Billing Personnel and must meet the education requirements.
PROCEDURE:
1.The facility Ethics and Compliance Officer (ECO) or Corporate Responsible Executive must designate an appropriate person (e.g., Local System Administrator, Department Director) to track the required education hours for each person involved in billing and/or billing-related services for Federal healthcare programs.
2.It is the responsibility of the direct supervisor to ensure that each person supervised who is performing billing and/or billing-related services for Federal healthcare programs receives the required eight (8) hours of billing education per calendar year.
3.The completion of billing education hours, as defined in this policy, must be tracked using the Company’s HealthStream Learning Center (HLC).
4.The designated person will be responsible for reporting completed 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.
  1. Any person involved in performing billing and/or billing related services for Federal healthcare programs who does not meet the designated time-frame for completion of the required eight (8) hours of training must be reported to the ECO by the person’s direct supervisor and must immediately complete the training before resuming job responsibilities. If the training is not completed within two business days of the designated time frame, the employee must be suspended without pay until the educational requirements are met.
The name of the person who did not meet the designated time frame in obtaining the required hours of billing training and the name of his or her direct supervisor must be reported by the ECO to:
  • the Division President, for a hospital employee; or
  • the Company’s President and Chief Operating Officer, Department Manager for an employee at the Corporate office; or
  • the FSD CEO, for a PAS employee; or
  • an individual in a position equivalent to the Division President, for an employee in any other setting.
The ECO must also include in his/her report, confirmation that an action plan has been developed for the person to complete the required training immediately.
  1. The Corporate Government Programs Department will issue a certificate to each person who attends training covered by this policy that is supplied by Regulatory Compliance Support. The certificate will identify the number of hours applicable towards this policy’s billing education requirement.
  1. The facility Ethics and Compliance Officer (ECO) or Corporate Responsible Executive must designate an appropriate person to distribute billing education and/or billing-related communication to the appropriate personnel in the facility. (e.g., an e-mail regarding the appropriate codes to use when billing for pulse oximetry must be distributed to all respiratory therapy staff.)
  1. The facility must be able to prove compliance with this policy when requested.
The Facility Ethics and Compliance Committee is responsible for implementation of this policy within the facility.
REFERENCES:
Coding Orientation and Training Policy, REGS.COD.005
Coding Continuing Education Requirements Policy, REGS.COD.006
Coding Orientation and Training for Outpatient Services Group Entities Policy, REGS.OSG.005
Coding Continuing Education Requirements for Outpatient Services Group Entities Policy,REGS.OSG.006

3/2007