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Employee Education Policy

Description: 

Please see the respective policy directly below.

SIU School of Medicine

SIU HealthCare

POLICY           

 

 

EMPLOYEE EDUCATION POLICY

 

Policy

 

It is the policy of SIU to provide employees involved in the claim development and submission process or in business activities which may be subject to the fraud and abuse laws with such training as may be reasonably necessary and appropriate to ensure material compliance with applicable laws relating to the submission of claims or SIU business relationships.

 

I.  Background

 

SIU is committed to ensuring that its billing policies and procedures adhere to all federal and state compliance regulations.  Towards this effort, SIU has approved a series of policies to meet the commitment. SIU collectively applies to the SIU School of Medicine (including the Federally Qualified Health Center (FQHC)) and the SIU HealthCare (SIUHC). 

 

II. Policy

 

The Compliance Training Program focuses on the following components: Fraud, Waste and abuse Training, General Compliance Awareness Training and Billing and Clinical Documentation Training.

 

A.  Fraud, Waste and Abuse Compliance Training

 

The first component, Fraud, Waste and Abuse (FWA) Training is designed to provide education to officers, directors, providers, and employees of SIU of statutes, regulations, and agency directives relating to their individual functions within SIU.  Training should include the standards of business conduct that such individuals are expected to follow and the consequences, both to the individuals and to SIU, that will ensue from any violation of these requirements.  Annual FWA training will be assigned to all clinical staff and providers. 

 

B.  General Compliance Training

 

Compliance is everyone’s responsibility and sets forth a code of conduct and emphasizes the institution’s commitment to “do the right thing.”    This course educates employees on how a compliance program operates and how compliance program violations should be reported.  All new employees will receive this training in orientation and this training will be incorporated into the annual training provided to SIU clinical staff and providers.

 

C.  Billing and Clinical Documentation Training

 

SIU will provide the following education to employees involved in the claim development and submission process:

 

1.  Billers/Coders/Charge Processors

 

Annual training relating to one or more of the following subjects:

 

SIU’s compliance program; an overview of the fraud and abuse laws as they relate to the claim development and submission process; a review of Medicare requirements applicable to the coding and preparation of claims; billing and proper documentation; and the consequences to individuals and SIU for failing to comply with applicable laws and regulations.

 

2.  SIU HealthCare, all Physicians and Surgeons Responsible for Billing Activities, Resident Physicians and other patient care personnel

 

a.  Annual  training relating to one or more of the following subjects:

 

SIU’s compliance program; an overview of the fraud and abuse laws as they relate to the claim development and submission process; a review of Medicare requirements relating to teaching physician presence and E/M guidelines and adequate documentation of both; charge entry and coding (as applicable); and the consequences to individuals and SIU for failing to comply with applicable laws and regulations.

 

b.  New Employee Training:

 

Plan providers, residents and SIU personnel who prepare, document or submit requests, and/or code services for reimbursement from patients, federal health care programs, and/or other payers must complete Billing and Documentation training.  Requirements for Training are as follows:

 

  • New providers will be required to take the training within 30 days of employment or within 30 days of their credentialing effective date (date provider number is issued), whichever is most recent.

 

  • New residents and SIU personnel with patient care and medical billing responsibility will be assigned the training within 30 days of their start date or employment.

 

D.  Standard Privacy Training – Health Insurance Portability and Accountability Act (HIPAA)

 

HIPAA Compliance falls under 45 CFR 164.530 of the Administrative Requirements of the Privacy Rule. A covered entity (SIU) must train all members of its workforce on the policies and procedures with respect to protected health information (PHI) required by this Rule and as necessary and appropriate for the members of the workforce to carry out their functions within SIU.

 

 

E.  Other Mandatory Training

 

There are a number of other safety and compliance trainings (See Appendix A) that are required for employees to be updated and trained on annually to meet federal and state regulations.  Other trainings are just required at new employee orientation.       

 

F.  Documentation  

 

SIU shall document the training provided to each employee.  The documentation shall include the name and position of the employee, the date and duration of the educational activity or program and a brief description of the subject matter of the training.

 

Educational activities include, but are not necessarily limited to, SIU sponsored programs or educational sessions; viewing educational videos; completion of online training modules; participation in department meetings in which compliance and claim development and submission process issues are specifically addressed; attendance at carrier, intermediary or state sponsored educational sessions; and attendance at seminars, workshops or similar educational sessions.

 

G.  Methods of Instruction

 

  1. Web-based modules
  2. In-service training
  3. Live or video seminars
  4. Dedicated Web site
  5. Grand Rounds
  6. Communication via periodic electronic mail, newsletter, or other means

 

H.  Sanctions

 

1.  Plan providers who fail to complete trainings within the aforementioned time frame will have billing privileges suspended.  Services during the billing suspension period will not be submitted to third party payers or private pay patients until the training is completed.  If a service is erroneously billed, charges will be adjusted or corrected, and any overpayment collected will be promptly refunded to the carrier or patient.  Billing privileges will be reinstated upon the provider’s completion of the required educational session.  The Compliance Officer will notify the Department Chair and Director of Patient Business Services in writing of suspension and reinstatement requirements.

 

2.  SIU personnel who fail to attend the training within the aforementioned time frame will be subject to disciplinary action imposed by the Office of Human Resources in consultation with the Dean of the School of Medicine, CEO of SIU Healthcare, Chief Medical Officer and the Compliance Officer.  A memorandum, outlining the disciplinary action, consequences of failure to attend a mandatory program, and requirements for remediation, will be sent to the employee by the Chief Medical Officer.  A copy will be maintained in the employee’s personnel file with a copy sent to the employee’s supervisor.

 

Adopted:  January 20, 1999

Contact:  Compliance Officer

Revisions:

Approved by OCP: 1/11/2017

Approved by Quality and Safety:  2/21/2017

References:

See Exhibit A

 

 

Exhibit A – Annual Mandated Training (Regulation or Policy)

Training

Mandated By

Education Source

Frequency

Time

AHEOP & Emergency Response Training

OSHA & IEMA

Campus Emergency Plan and Violence Prevention Plan

NEO/ Annually

.5 hrs

Asbestos

Asbestos Abatement; OSHA

General Industry

Annually (specific staff)

2 hrs

Basic Electrical and Power Tool Safety

OSHA

OSHA

NEO once (CPSO only)

.25 hrs

Blood borne Pathogens training

OSHA

Occupational Exposure Control Plan

NEO/ Annually

.25 hrs

Chemical Hygiene/ Lab Safety

OSHA

Lab Standard (Chemical Hygiene Plan)

Annually (specific staff)

1.5 hrs

Confined Space Entry

OSHA

OSHA

NEO once 

.75 hrs

Emergency Group Leaders & Alternates

OSHA

Emergency Action Plan

Annually (specific staff)

.5 hrs

Fire Extinguisher Use

OSHA

Portable fire extinguisher

Annually (specific staff)

.25 hrs

Hand Hygiene

OSHA & CDC

Occupational Exposure Control Plan

NEO/ Annually

.25 hrs

Ladder/ Lift Safety

OSHA

General Duty Clause

NEO once (specific staff)

.25 hrs

Lockout/ Tag out

OSHA

OSHA

NEO/when necessary

.5 hrs

RAVE System

OSHA

Emergency Action Plan

NEO once

.5 hrs

Occupational Noise Exposure

OSHA

SIU Hearing Conservation Program

Annually (specific staff)

.75 hrs

Tuberculosis

OSHA

Tuberculosis Control Plan

Annually (specific Staff)

.25 hrs

DOT HazMat Security

DOT

SIU Hazardous Materials Security Policy

Once to specific staff

.25 hrs

DOT/IATA Shippers

DOT

SIU Hazardous Materials Security Policy

Every 2 years (specific staff)

2 hrs

Powered Industrial Trucks

Federal

Federal

NEO once(specific staff)

1.25 hrs

Respiratory Protection Program

Federal

Respiratory Protection Program

Annually (specific staff)

.75 hrs

SDS/ ChemWeb viewer

Hazard Communications Standard:  Material Safety Data Sheets

Hazardous Communication Standard

NEO once

.5 hrs

Slips, Trips, and Falls

Federal

General Duty Clause

NEO once

.25 hrs

Lifting Ergonomics

Federal Recommendation

Federal

NEO (CPSO & Security)

.75 hrs

HIPAA Initial

Federal & State of IL

HIPAA Procedure Law

NEO/Once

1 hr

HIPAA Update

Federal & State of IL

HIPAA Procedure Law

Annually

.25 hr

MSDS Online Site Manager

Federal

Hazardous Communication Standard

One time training

.5 hrs

Violence against Women

Federal

Federal

NEO Once

1 hr

Sexual Harassment

Federal

Federal

NEO Once

1 hr

NIMS ICO Named Members Training

State of IL

Illinois Campus Security Enhancement Act

Once (specific staff)

.75 hrs

NIMS ICO Support Staff Training

State of IL

Illinois Campus Security Enhancement Act

NEO (CPSO)

.5 hrs

Occupational Exposure to Lab Animals

AAALAC Recommendation

AAALAC

NEO (DLAM)

.25 hrs

Radiation Awareness Training

State of IL

IEMA

NEO once

.25 hrs

Radiation Support Staff

State of IL

IEMA

Annually (specific staff)

.5 hrs

CB Online Training

SIU

SIU

NEO Once (Inquiry Access)

3 hrs

CB Universe

SIU

SIU

NEO Once (Clinical Staff)

5 days

CEMR

SIU

SIU

NEO Once (Clinical Staff)

1/2 day

Secure Messaging

SIU

SIU Security Policy

Once (specific staff)

.5 hrs

Medical Record Standard

SIU

SIU Medical Record Policy and Procedures

Annually (EHR users)

.75 hrs

Workplace Violence Prevention

 Federal

Federal

NEO Once

1.5 hrs

Ethics Training

State of IL

State of IL

Annually and NEO within 30 days of hire

1 hrs

Fraud, Waste and Abuse Training

Federal & Contractual

Federal CMS

Annually and NEO

.25 hrs

General Compliance Training

Federal and Contractual

Federal CMS

Annually and within 90 days of hire

.50 hrs