Best Practices: Annual Reviews
By Scott C. Spradling, certified administrator
It is a new year and if you are anything like me, I was happy to ring in 2016 satisfied that I survived the transition to ICD-10. While most of us spend most of January closing out and analyzing the past year, it is also a great opportunity to dust off and review your practice’s major policies, procedures, and programs, such as human resources/employee relations, operations, and compliance.
Unless you have a fairly regular turnover of staff or have been on a growth hiring spree, the employee manual rarely gets a second thought after the first new hire orientation. However, because of its importance to all things employee/employer related, it certainly deserves a review annually. Have the sections been updated to reflect the current practices of the company? Have there been any management decisions throughout the previous year that could affect the subject matter contained in the manual? For instance, perhaps you have a section on professional continuing education and it cites the amount that will be afforded to each practitioner annually. However due to budget and reimbursements a management decision was handed down to reduce that amount by “x”; if it is not updated in the employee manual, an employee could argue that they are entitled to the amount as stated in the employee manual that they were given and signed acknowledgment of receipt. Any subsequent changes that need to be made to the manual annually should be outlined clearly for ease of reviewing by employees, and annually, employees should acknowledge receiving the updated manual. I recommend highlighting any major changes/additions at the first staff meeting of the new year, and have all employees re-sign at that time. This is also a good time to update and outline employee benefits, which are often listed within the employee manual. For instance, changes to health benefits, paid time off, retirement benefits, or paydays, to name just a few.
As an administrator of a private practice physical therapy group, it is a fair assumption that you likely do many things daily as part of the operation of the practice. If it is not something you do directly, it is likely something you have delegated to an administrative colleague. My practice owner reminds me often of my ongoing good fortune of having not been hit by a bus and that it “could happen”. I notice most do not say “what happens if you quit or are fired or retire” it’s always “what happens if you get hit by a bus tomorrow, where does that leave us?” Setting aside the anxiety of my impending mortality, it is fair to say, a good practice is one that operates regardless of who is performing the task. An even better practice is one where at least two people knows the what and the how of what the other does on a daily basis. The wheels should never stop turning in the absence of a staff member. A well-defined operations manual should be in place and should be updated annually to reflect current practices as well as those personnel who are the primary and secondary responsible parties for the procedure. For instance, the procedure of verifying a patient’s insurance coverage and benefits should be efficient and effective. It should also indicate that “employee x” is the primary staff member responsible and “employee y” is the backup person (should Bill also suffer from the dreaded “what if…bus” analogy). This should be for all areas that effect the operations of the practice. So often I hear people say, “well that is a management thing, we do not know what is done.” We are not selling State secrets here; it is physical therapy and the business of running a good physical therapy practice. There should never be an atmosphere of “only he does this” or “we do not know how that gets done.” As an administrator, I am glad someone can do my work if I am not in; it means I can actually take a vacation every now and then.
Compliance is that evil necessity that simply will not go away. We hate it, we curse it, we fear it, and yet we know if we ignore it, we risk everything under our roof. The two areas that stand out are documentation and the Health Insurance Portability and Accountability Act (HIPAA). Your documentation compliance policy/program should be reviewed annually to reflect critical changes in Medicare and your contractual payers. There are so many changes throughout the year that rather than trying to create a manual that needs constant updating, have your basic policy outlined with your practices minimum standards and guidelines and then have a section for each of your contractual payers with reference as to where to find their online material and an archive of their posted updates. This should also be reviewed and “edited” so as not to keep decades of information that is no longer valid. Your policy/program need only be updated with the more major of changes, for instance when Medicare adopted the functional limitation reporting (FLR) “G” codes, we updated our practice minimum standards with regard to Medicare documentation to include FLR “G” codes. I consider major updates to be anything that has the ability to delay or deny my reimbursement from a payer. HIPAA is that other area of compliance, much like a distant relative you forgot you had one until they show up on your doorstep. Thankfully there are several companies that offer “HIPAA in a Box” and for a relatively modest fee, they can set you up and keep you up to date. Look for a company that includes updates in its packages.
It is a lot of work to be sure, but by setting up a realistic annual schedule for the review and update of these areas, you will find you end up with less “catchup” work overall and it will help you plan for the year to come. This will free you up throughout the remainder of the year to handle the unforeseeable zingers that we call the health care system.
Scott C. Spradling is a member of the PPS Administrators Council and a certified administrator since 2011. He is the administrator of Movement Systems Physical Therapy in Seattle, Washington, and can be reached at sspradling@movementsystemspt.com.