The Need for a Policies/Procedures Manual

Having a policies and procedures manual is becoming a necessity , not an option, for private practitioners. While the Joint Commission mandates that therapy departments in hospital settings have such manuals in place, more private practices are seeing that they also need to find a way to systematically comply with all state and federal requirements and manage day-to-day operations.

While the core of any private practice is clinical care, an efficient and compliant back-office business operation is the backbone and infrastructure through which services are rendered. Having defined policies and procedures can protect your practice and serve as a valuable tool for risk management and quality assurance.

Many insurance carriers now require participating providers to have a policies-and-procedures manual in place, as do many government-funded programs and contractual bidders for therapy services. The penalties imposed on practices for deficient or improper billing, coding, receipt of funds, kick-backs and insurance fraud are warning signs that every practice needs to ensure consistently compliant operations. Without defined policies, staff are left to make them up as they go along, with practice owners backpedaling to institute them after, not before, they are needed.

Policy vs. Procedure

A policy reflects the guiding philosophy and general rules that will ultimately govern procedures. Policies are wide-reaching expectations upon which action-oriented decisions will be made. Essentially, a policy determines the "who, what, when and where" about a particular aspect of a practice.

A procedure sets forth, in detail, a specific way to accomplish an action that becomes a method for doing business. Procedures may describe how to carry out a policy.

For example, a no-smoking policy may state that all areas of the private practice are designated as non-smoking areas. The procedures would detail the mechanism for enforcement, including signage and what to do in the case of violations.

What to Include

Your manual will depend on the specifics of your practice, and you should begin by developing a checklist. Remember, this is not the place to include clinical protocols. Policy and procedure manuals should be written in user-friendly language, emphasizing expectations. The more accessible you make it, the more likely it will be used, so consider both a hard-bound and online version.

Generally, your manual should include the following sections:

• Client Processes: Registration and intake for new patients, insurance verification, scheduling, and referral management, permission authorizations, patient rights.

• Payment Processes: Payment schedules, fee structures, assignment of benefits, management of co-payments, deductibles, co-insurance, refunds, credit card/check management and verification, collections, hardship determinations.

• Coding/Billing/Accounts Receiveable and Accounts Payable Processes: Typical code sets (ICD-9/CPT), submission of claims, use of advance beneficiary notices (ABNs), therapy caps, electronic and paper claims processes, management of explanation of benefits (EOB), deposit management, payment receipt, appeal of denied/pending claims.

• Records and Information Management: Initial and ongoing guidelines for writing treatment notes, patient-record retention and storage, HIPAA and FERPA compliance, identity-theft guidelines, disaster-recovery plan, record review.

• Miscellaneous: Abuse recognition and reporting, risk audits and assessments, satisfaction surveys, IT system maintenance and back up, human resources management, employment guidelines/handbook, infection control and universal/standard precautions, staff screening and training, guidelines for yearly manual review and revision.

Any manual should be regularly reviewed and updated, used to train employees, and should serve as a reference guide for day-to-day operations. You may need to add to it as your practice grows, or as state and/or federal regulations change over time. Including staff in a yearly review of your manual can help foster their commitment to its use. n