A whole-of-practice approach to Medicare compliance

A regular column to assist members to meet third party requirements

While the individual holder of a Medicare provider number is legally responsible for any claims made using that provider number, in many psychology practices, it is the administrative staff within the practice that undertake the day-to-day billing operations. To reduce the risk of inaccurate billing, it is therefore helpful to adopt a whole-of-practice approach to Medicare compliance.

Such an approach is predicated on developing a positive compliance culture within the practice. This means that all staff in the practice understand the importance of compliance and there is a culture that encourages prompt reporting of compliance concerns. In addition to developing an agreed and publicly displayed set of Medicare billing compliance values, practices should consider having documented policies and procedures (an ‘instruction manual’) that set out the responsibilities of all staff including Medicare billing training requirements, the consequences of incorrect billing or non-compliance for psychologists, procedures for reporting concerns about compliance, and the process for reviewing billing practices.

Developing a culture that supports voluntary disclosure when incorrect billing occurs facilitates early correction of an error. The voluntary acknowledgment of an error to the Department of Human Services may still lead to the requirement to repay the incorrect amount received but could avoid an additional substantive administrative penalty. There is a Voluntary Acknowledgement of Incorrect Payments form available at http://www.humanservices.gov.au/health-professionals/forms/. Psychologists and administrative staff within a practice should be encouraged to raise any concerns about incorrect billing. It can be helpful for the ‘instruction manual’ to document to whom in the practice staff should take their concerns and to consider how to minimise any staff fears of being perceived to be a whistle-blower. Open communication between practice management, psychologists and practice staff can assist to develop a culture of information sharing and problem-solving.

Lack of up-to-date knowledge of Medicare billing requirements often underpins unintentional compliance breaches. Most newly qualified psychologists and those new to private practice including office staff are likely to require substantial training in correct Medicare billing and may also be unaware of the significant financial, administrative, reputational and legal consequences of incorrect billing. Having documented procedures for billing within a practice can make it easier to train new administrative staff and psychologists. The ‘instruction manual’ could also contain the administrative processes for record keeping required to substantiate a Medicare claim.

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