Having a policy and procedure manual is becoming a necessity, not an option, for private practitioners. While therapy department in hospital settings are mandated by the Joint Commission to have one in place, more practices are seeing that they also need to a way to systematically comply with all state and federal requirements, and manage day to day operations. While the core of any private practice is clinical care, an efficient and compliant back office business operation is now the backbone and infrastructure from which services are rendered. Having defined policies and procedures can protect your practice, and serve as a valuable tool for risk management and quality assurance.
Many insurance carriers now require that participating providers have a policy and procedure manual in place, as do many government funded programs, and contractual bids for therapy services. The penalties imposed on practices for deficient or improper billing, coding, receipt of funds, kick-backs and insurance fraud are warning signs that every practice needs to have in place, policies and procedures to ensure consistently compliant operations. Without defined policies, staff are left to make them up as they go along, with practice owners back pedaling to institute them after, not before, they are needed.
Policy versus Procedure
A distinction needs to be made between a policy and a procedure . A policy will reflect the guiding philosophy and general rules that will ultimately govern procedures. Policies are wide reaching expectations upon which action oriented decisions will be made. Essentially, a policy will determine the “who, what, when and where” about a particular aspect of a practice. A procedure will set forth, in detail, a specific way to accomplish an action that becomes a method for doing business. Procedures may describe in a step by step fashion exactly how to carry out a policy. So while a No Smoking policy may state that all areas of the private practice including waiting treatment rooms are designated as non smoking areas, the procedures for enforcement will detail the mechanism for enforcement including signage and what to do in the case of violations.
What to Include
Your manual will depend on the specifics of your practice, and you should begin by developing a checklist. Remember that this is not the place to include clinical protocols. Policy and procedure manuals should be written in user friendly language, emphasizing expectations. The more accessible you make it, the more likely it will be used, so consider a hard bound and online version. Generally, it should include the following sections:
- Client Processes – Registration and intake for new patients, insurance verification, scheduling, and referral management, permission authorizations, patient rights
- Payment Processes – Payment schedules, fee structures, assignment of benefits, management of co-payments, deductibles, co-insurance, refunds, credit card/check management and verification, collections, hardship determinations
- Coding/Billing/AR and AP Processes – Typical code sets ( ICD-9 / CPT), submission of claims, use of ABNs, therapy caps, electronic and paper claims processes, management of EOB, deposit management, payment receipt, appeal of denied/pended claims
- Records and Information Management – Initial and ongoing treatment note writing guidelines, patient record retention and storage, HIPAA and FERPA compliance, identity theft guidelines, disaster recovery plan, record review
- Miscellaneous – abuse recognition and reporting, risk audits and assessments, satisfaction surveys/call backs, IT system maintenance and back up, human resources management, employment guidelines and handbook, infection control and universal/standard precautions, staff screening and training, guidelines for yearly manual review and revision.
There is no value to a manual that is outdated or irrelevant. Any manual should be regularly reviewed and updated , used to train employees, and serve as a reference guide for the day to day operations of your practice. You may need to add policies and procedures as your practice grows, or as state and/or federal regulations change over time. Including staff in the yearly review of your manual can help foster their commitment to its use. Having a usable up to date manual can help you meet and reflect your compliance with applicable state and federal requirements.