As part of the Yale School of Medicine's commitment to medical billing compliance, a confidential hotline was implemented in October of 1998. The hotline is a simple way for employees to anonymously report concerns that may involve potential violations of medical billing regulations. Recent information has suggested that employees may not be aware of:
- Who can use the Hotline?
- What is the purpose of the hotline?
- What is medical billing compliance and how does it apply to me?
- What happens when an employee calls the hotline?
Calls to the hotline can be made anonymously.
This Special Edition of the Alert newsletter is being distributed in the hopes of answering the above questions so that employees will become more familiar with the hotline.
Who can use the hotline?
All employees, both faculty and staff, may use the hotline. This includes all employees in the Clinical Departments, Patient Financial Services, including offsite practice locations. The hotline is not intended for use by patients and patients should not be directed to call the hotline. Patient inquiries and complaints should be handled by Patient Financial Services staff and/or supervisors. Patient inquiries regarding whether services billed were rendered should be referred to the Administrator in the Clinical Department and the Compliance Officer.
What is the purpose of the hotline?
The hotline is available to you for those situations that are related to compliance with medical billing regulations. The hotline is an avenue of reporting available to all employees in the event that:
- you do not feel comfortable bringing your concerns to your supervisor, or
- you have brought your concerns to your supervisor and you were not satisfied with the action or possibly lack of action taken
What is medical billing compliance and how does it apply to me?
Many individuals are involved in the culmination of a bill for medical services. From the moment the patient calls for an appointment, the sequence of events and University employees involved provide a means for the generation of a bill for medical services. Some of these employees include: schedulers, registrars, medical secretaries, clinical practice specialists, nurses, physicians, lab and x-ray technicians, transcriptionists, charge entry personnel and insurance follow-up representatives. While ties to medical billing seem more evident for some of these job positions such as charge entry, all employees have a collective responsibility to insure that patient and service information gathered during the process is accurate and results in an accurate billing. If a situation makes you uncomfortable, don't just assume that someone `higher up' must have approved the situation.
Examples of medical billing compliance issues may include recurring or intentional situations involving:
- Billing patients for amounts that they are not responsible for
- Identifying a system problem which may result in incorrect bills
- Improper allocation of credit balances
- Billing for services under the wrong patient's account
- Billing for a service that is not documented
- Up-coding or billing for a procedure using an incorrect procedure or diagnosis code
- Services intentionally billed under the wrong physician
These situations do not involve medical billing compliance:
- Patients inquiries or complaints about their bill
- Human resource issues or employee relation problems
What happens when an employee calls the hotline?
Compliance Line is an outside, independent company that is not affiliated with Yale University. When you call Compliance Line, a trained communication specialist will answer and handle your call. You are not required to identify yourself. The communication specialist will take your information and provide a report to the Director of University Audit. You will be provided with a special call back number so that you can re-contact Compliance Line to get an update on the status of your report. The Director of University Audit will review and evaluate the report and undertake steps to follow up on the report. Any employee who contacts the hotline in good faith and reports possible compliance issues will not be subject to retaliation or harassment for the report.
We recently interviewed several Yale employees from Patient Financial Services and the Clinical Departments regarding the hotline. We asked the employees what they knew about the hotline. We conducted two test calls to the hotline so the employees could see first hand how the hotline works. The employee's comments after hearing the test calls included statements such as:
The calls were handled professionally. Compliance Line was friendly and helpful. The operator was courteous and did not press for the caller's identity or for answers to questions the caller declined to answer. The operator sounded knowledgeable and confident.
While we encourage you to bring any concerns regarding medical billing compliance to your supervisor or other appropriate management, we want all employees to recognize that Compliance Line is available as an alternative. If you have any questions regarding the hotline, please contact Judy Harris, Compliance Officer, at 785-3868 or judy.harris@yale.edu.