Compliance Education

STANDARD

The USC Office of Culture, Ethics and Compliance has the responsibility for the oversight of the education and training curriculum on coding, documentation and compliance related issues. 

Clinical Department-Specific Educational Requirements:

• On an annual basis, each Clinical Department will sponsor formal compliance training in:
  • coding and documentation
  • trends of monitoring findings
  • identified specialty specific risk areas
  • new regulatory requirements
  • other compliance related matters
• Annual Clinical Department compliance education must be coordinated with the Office of Culture, Ethics and Compliance and conducted by an approved Certified Coder Monitor or other instructors, as approved by the Office of Culture, Ethics and Compliance.  Attendance must be taken and documentation maintained by the respective Clinical Department and submitted to the USC Office of Culture, Ethics and Compliance.

Curriculum:

• All educational materials developed for annual education must be submitted to the USC Office of Culture, Ethics and Compliance at least ten days prior to the session for review and approval prior to delivery of the education.
• All educational materials whether developed internally or externally need to contain the name and credentials of the instructor, the date and title of the session, as well as learning objectives. Materials must contain sufficient detail so as to serve as adequate education when distributed to providers unable to attend the education forum. References to authoritative sources should be included as appropriate. Authoritative sources are defined as the American Medical Association’s (AMA) CPT Assistant, as well as the Centers for Medicare and Medicaid Services (CMS) Carrier Manual, the Regional Medicare Administrative Contractor, Medi-Cal and/or the Federal Register, etc. Clinical Departments and monitors need to be cognizant and aware of reproducing, copying and distributing material that is copyrighted (e.g. Part B News, CPT Assistant, etc.)

All educational materials must be distributed to physicians who are not able to attend. It is preferable that an absent physician meet one-on-one with the Certified Coder monitor, Compliance Liaison, or Office of Culture, Ethics and Compliance, whichever is applicable, to review the material presented.

Provider Specific Educational Requirements:

Upon hire each provider is required to successfully complete the educational billing compliance module. Additionally, at time of reappointment, each provider is required to successfully complete an additional billing compliance module.

Additional provider specific education will be provided to all billing providers subsequent to the completion of monitoring as described in Standard MA-500.

QUESTIONS

Questions regarding policies, procedures or interpretations should be directed to the USC Office of Culture, Ethics and Compliance at (323) 442-8588 or USC Report & Response at (213) 740-2500 or (800) 348-7454.