Contract Therapy Compliance
Managing Your Risk With Therapy Vendors

Managing RiskBecause compliance and quality risks can be so costly to any facility and your vendor may not be insured in all circumstances, you should thoroughly understand the vendor’s approach and program. The following 12-point check list can help you at contract time or right now.

  • Code of Conduct. Examine your vendor’s written Code of Conduct. As you know, a Code of Conduct is the cornerstone of most Compliance Programs. If your vendor does not have one, they may not have the requisite sophistication to protect your interests.
  • Credentialing. Ask your vendor to describe their credentialing process and furnish their checklists. Ensure that they complete all necessary background checks including an annual review of the OIG Exclusion List.
  • Compliance Program. Have them describe their Compliance Program and ask if they require an Annual Attestation of the Program.
  • Compliance Reporting. Find out how employees of your vendor can communicate compliance concerns. What is their hot line number?
  • Productivity. Ask your vendor to represent the target productivity of the treating staff, both individual and aggregate. Excessive productivity may not be to your or your patient’s benefit (it may be to the vendor). Understand how much therapy is one-on-one versus concurrent therapy.
  • Denials Management. Review your vendor’s Denials Management contractual obligations.
  • Documentation. Be familiar with how your vendor reviews and manages documentation.
  • Compliance History. Inquire as to your vendor’s history in managing denials and probes. Talk with those client administrators.
  • Tone At The Top. When talking to your vendor, make a personal judgment regarding management’s setting of the proper tone for your compliant, quality program.
  • Pricing Models. Understand what types of behaviors (i.e. concurrent therapy, extreme productivity, dropping service, etc.) your therapy vendor’s pricing model incentivizes.
  • Cost. Be aware of the true cost of service and what is being charged. The lowest price quote does not always mean the lowest cost.
  • Service Delivered. Understand how much time the therapist will really be in the facility and what compromises, if any, will be made to patient care as a result.

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