From
Caroline Siskowic
Title
Fire Compliance Officer
Presenter
Robert Fite, Fire Chief
Recommended Action
Approve
Analysis
This is a new position in the Fire Department to be paid utilizing funds received from the state for the Texas Ambulance Supplemental Payment Program. This position would ensure claims filing, patient billing and HIPAA (Healthcare Insurance Portability and Accountability Act) compliance. Primary duties would include an annual risk assessment in both HIPAA and claims filing, develop and maintain a compliance plan, policies and procedures for billing and health information privacy, perform routine claims audit, oversee billing staff, oversee TASPP (Texas Ambulance Supplemental Payment Program) submission, oversee external billing review, manage up to date BAA's (Business Associate Agreements) per HIPAA, exclusion checks and follow up for personnel, vendors and other entities involved with patient care and/or billing. This is an exempt position, pay grade 614. This position was a compliance deficiency during the 2015-2016 HIPAA and Billing Compliance review conducted by consultants Page, Wolfberg and Wirth.
It is the Fire Department's recommendation to employ a dedicated Compliance Officer that would also over see the EMS Billing Division. With the advanced auditing by federal and state agencies, frequent changes in federal and state rules and regulations along with the severe penalties for errors in claims filing and HIPAA, it is more cost effective to staff a dedicated Compliance Officer than to be found out of compliance. According to the Dallas Business Journal, August 26, 2011, http://www.bizjournals.com/dallas/news/2011/08/25/10-north-texas-cities-to-pay-for.html, cities that have settled with federal and state governments for coding violations include Dallas (fine $2.47 million in 2011) and 10 other North Texas cities ($1.69 million combined) under the False Claims and Medicaid fraud claims. Many other businesses have been audited and assessed severe penalties for various violations of the false claims act, anti-kick back statute and HIPAA. Correct interpretation of rules and regulations along with employing a dedicated Compliance Officer is a huge advancement towards ensuring full state and federal compliance to claims filing and HIPAA compliance.
Financial Consideration
Funding of $374,191 is available in the Fire Department's TASPP trust account 334691.