Director of Billing Compliance

The Group Lead Compliance has primary responsibility for the Company’s medical billing and coding compliance. Collaborates with multiple departments within the company, especially within TruBridge CBO and Coding divisions, to develop a medical billing and medical coding audit plan utilizing governmental resources.  Adjusts the audit plan periodically as compliance guidance and/or risks change.  Develops tools to conduct audits and aggregate audit results.  Coordinates with leaders overseeing staff conducting medical billing and medical coding audits to ensure audits are conducted upon high-risk areas as per the auditing plan for those areas.  Provides education to staff performing duties impacting claim submission (medical billers and medical coders) and collections (payment posters and collectors).  Provides compliance education to staff who train and/or audit employees performing medical billing, coding, payment posting, or collection activities.  Alerts TB EHR, TB Encoder, and/or TB RCM programmers when a medical billing or coding product does not perform compliantly or is impacted by publication of new Federal or State rules.

These Goals and objectives are not to be construed as a complete statement of all duties performed; employees will be required to perform other job-related duties as required.  Goals and objectives are subject to change.

All activities must comply with Equal Employment Opportunity laws, HIPAA, ERISA and other regulations, as appropriate. 

Essential Functions: In addition to working as prescribed in our Performance Factors specific responsibilities of this role include:

• Collaborate with the various departments in the Company who conduct or impact medical billing, medical coding, or collection services to develop policies and procedures that establish standardized compliant billing, coding, payment posting, and collection practices that satisfy governmental regulation.  This is done in consultation with official published mandates and guidance, such as Office of Inspector General (OIG) Guidances, Federal Register, and CMS publications pertaining to medical billing, coding, and collection compliance, and under the supervision of the Corporate Compliance Officer.
• Accept reports of audit findings conducted upon medical billing, coding, payment posting, or collections services provided by TruBridge.  These audit findings can be from internal audits conducted by TruBridge upon itself or from external parties who conduct audits upon medical billing, coding, payment posting, or collection services conducted by TruBridge.  Aggregate this data and summarize for reporting to the Medical Billing and Coding Compliance Committee, Governance Risk and Compliance Committee (GRCC), and Board of Directors.
• Assist TruBridge staff and clients of TruBridge’s medical billing, coding, payment posting, or collections services in responding to internal and/or external audits pertaining to these areas.
• Develop educational materials pertaining to medical billing, coding, payment posting, and collections; submit to the Corporate Compliance Officer for approval, publication and deployment to board members, employees, and/or contracted staff upon hire, for annual in-service, and/or as needed throughout the year. 
• Develop a medical billing and coding audit plan annually, adjusting throughout the year as needed, utilizing OIG and Centers for Medicare and Medicaid Services (CMS) resources to identify “high-volume, high-risk” areas.
• Develop tools used to conduct audits and aggregate audit results.
• Educate auditors on risk areas identified, usage of auditing tools, and proper auditing technique.
• Ensure the proper number of audits per employee and per site are conducted as prescribed in company policies.
• Identify employee education needs based on audit results; coordinate the creation of educational materials and deployment of said education.
• Collaborate with all software divisions/departments of CPSI (EHR software, medical billing software, coding software, collection software) whose product contains features impacting medical billing, coding, and collections services to ensure such products do not contradict compliance with regulations pertaining to medical billing, coding, and collections.
• Collaborate with all software and service divisions/departments of CPSI providing medical billing, coding, clearinghouse, and collections activities to monitor OIG, Federal Register, CMS, MAC, and other compliance resources to keep abreast of Federal changes impacting billing and reimbursement.  Ensure staff are aware of and prepared for impending changes.
• Serve as the point person (with a backup) to whom company employees forward information learned or received relating to medical billing, coding, and collection compliance (examples of billing or coding errors identified, changes in billing or coding requirements, educational material pertaining to medical billing or coding compliance); summarize and disseminate said compliance information to applicable staff.
• Develop a central repository for compliance literature/resources for medical billing and coding staff.
• Work closely with Educational departments of the company to develop and deploy educational material and instruction as applicable.
• Alert TB EHR, TB Encoder, and/or TB RCM programmers when a medical billing or coding product does not perform compliantly or is impacted by publication of new Federal or State rules

Minimum Requirements:

Education/Experience/Certification Requirements

• Familiarity with Medicare billing guidelines, such as Medicare’s Secondary Payer rules, 72-hour, Advanced Beneficiary Notice (ABN) requirements, incident-to definition, modifiers that could be problematic for billing compliance (59, 25, KX), unbundling, Part B only, reference lab billing
• Excellent communication (written and oral) and interpersonal skills
• Strong organizational, multi-tasking, and time-management skills
• Detail-oriented and able to follow through on issues to resolution
• Able to act both independently and as a team member
• Open-minded and able to collaborate with all levels of staff (subordinates, peers, management) and consider all suggestions in developing best practices
• Minimum of Intermediate level of Excel experience
• Comfortable speaking in a group setting
• Able to present audit findings in a confident and constructive manner

Preferred Qualifications:

• Any healthcare compliance certification (CHC, CPCO)
• Prior position performing or responsible for the oversight of one or more of the following tasks:  medical billing and/or coding audits; response to RAC, ZPIC, or OIG audits or Corporate Integrity Agreement; research in the area of medical billing and/or coding regulations and guidance
• Prior Medicare billing experience in an acute care facility
• Critical Access Hospital (CAH) billing experience

Working Environment/Physical Demands

Working Environment:

• General office environment: Works generally at a desk in a well-lighted, air-conditioned cubicle/office, with moderate noise levels. 
• Periods of stress may occur.

Physical Demands:

• Activities require a significant amount of sitting at office and work desks and in front of a computer monitor.
• Some walking and standing relative to interaction with other personnel. 

Travel Requirements:  NONE

    None          Occasional           Moderate           Frequent           Very Frequent

                        (25% or Less)            (25% - 40%)                 (40% - 80%)                    (80% or more)

Other possible Unofficial Titles:

Unofficial titles may be given by the manager and used for calling cards and email signatures.

Note: Nothing in this job description restricts management’s right to assign or reassign duties and responsibilities to this job at any time. This document does not create an employment contract, implied or otherwise.  It does not alter the "at will" employment relationship between the company and the employee.

Management