Y2K is a compliance officer’s job, too
Y2K is a compliance officer’s job, too
You may not be a techie. The closest you come to dealing with computer systems may be watching Star Trek on TV. Even so, don’t expect information services or risk management to take up all the slack when it comes to dealing with the year 2000 computer bug; if you’re a compliance officer, it’s your problem, too.
As of today, carriers and intermediaries are subject to a HCFA directive not to pay claims that aren’t submitted in a Y2K-compliant format using an eight-digit date field. But this is not just a question of billing snafus that stop your institution from getting paid by HCFA, warns Dan Rode, technical director for the Healthcare Financial Management Association in Washington, DC. Remember that the Y2K bug involves software that may have nervous breakdowns because it thinks the year 2000 is really the year 1900. Suppose your billing software suddenly can’t track birth dates, and you don’t know who’s old enough to be Medicare-eligible. Or suppose dates of service become erratic, and you can’t track which claims fall within the 72-hour DRG payment window. At the least, HCFA may not accept your claims; at worst, persistent problems could be considered negligent for purposes of a False Claims Act suit. "We try to steer people away from thinking this is a technical issue," says George Kruth, Y2K project manager for fiscal intermediary Veritas in Pittsburgh. "It’s also a business issue."
Indeed, Veritas is planning special audits around Jan. 1, 2000, to check claims for accuracy of coding and other factors, says Kruth. "We will look at everything once, twice, three times, and once more," he adds.
Compliance officers may not be able to fix billing systems, but they can approach Y2K from the standpoint of due diligence, says Rode. They need to make sure their institutions have a Y2K plan, and equally important, they need to be sure there’s documentation to show what steps have been taken to test and fix systems. Given a lack of time and technical resources as providers scramble to meet the millennium, hospitals are more likely to focus on fixing their billing systems and all the ancillary systems that feed into it, such as those for pharmacies and labs. But they also need to have edits in place to verify that claims are processed correctly. If they don’t have the time to install computer edits, they may have to consider manual audits, says Rode.
If you get assurances from vendors that your systems have been tested for the Y2K bug, make sure those assurances are documented, says consultant Elizabeth Wheeler, at Superior Consultants in Southfield, MI. If the vendor tells you to get that information from its Web site, you’d better print out those pages for your records. "Many people think you can go to these sites and jot the information down in a notebook," Wheeler adds.
HCFA has established a toll-free Y2K information hotline at 1-800-958-HCFA. For a useful Web site on Y2K and health care, check out the Rx2000 Solutions Institute page at www.rx2000.org. If you need software that will help you transmit your claims forms in a HCFA-compliant fashion, contact your intermediary or carrier for a free copy.
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