Case Study 8

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Case Study 8

  • The setting is a billing office in a laboratory where two or more clerks work together in very close proximity with each other, so that each can easily see what the other is doing. A billing clerk notices that one of his fellow employees is changing or adding codes to requisitions he is processing. This employee is a friend of his and he knows that he really needs the job at the laboratory because he is a single parent raising two kids. He also knows that what the employee is doing is against the company's compliance policies.
  • He asks the employee about it and is given the explanation that because the computer requires something to be entered in the ICD-9 code field and he only does this with non-Medicare patients, it doesn't matter. The employee explains that it saves him a lot of time he uses to call to get codes for the Medicare patients. What should this clerk do about this?
  • Correct Answer: She should talk to the supervisor about the problem even if she talks to the employee about it and the employee says she will talk to the supervisor and stop doing it.
  • Discussion: Every employee who becomes aware of a violation of the law or a compliance policy has a responsibility to take action, which includes reporting the problem to a supervisor or the compliance officer. It doesn't matter that these patients are not Medicare patients, the important thing is that the employee is violating a compliance policy. If this employee does not report the problem he is himself violating a compliance policy. If it is subsequently discovered that he knew and didn't report it, he could be terminated. If there is a need for refunds to be done or other action, it will not occur and could create a big problem for the lab in a subsequent audit or other action.