How to Create Therapy Clinic Policies That Support Credentialing Requirements
Rather than being that one thing you dread doing as a clinic owner, what if credentialing were something that practically took care of itself?
When you put systems in place, this can be exactly what it feels like: just another part of your clinic’s regular routine. Believe it or not, there are ways to delegate this big job to other members of your staff without losing efficiency and accuracy or compromising your patients’ continuity of care. In order to do so, you’ll need to build policies that support easy management of all the tasks involved in credentialing for your practice, specific to the licensure your therapists need to remain active.
No matter which state you operate in or which insurances you bill, HIPAA compliance is a non-negotiable for therapy clinics. Thus, best practice is to ensure you have policies in place that serve as reminders of the daily risks involved in handling sensitive data. Send out regular memos to your staff about how to safely email Protected Health Information (PHI). Assign a staff member to manage password changes and check that all electronic devices in your office are password-protected. It’s worth spending the time to address these risks up front and get all staff on the same page by providing ongoing HIPAA training.
Parallel to the major factor of HIPAA compliance are all of your clinic’s other internal procedures, which should reflect what’s required by your state Medicaid or Medicare agency and any commercial providers with whom you’re credentialed. For example, per CMS regulations, your therapist’s treatment notes and evaluations need to be signed within 48 hours of a completed session. One option is to require that supervisors check at the end of each day to verify that newly created documents are being signed in a timely manner, assuming they have access to electronic documents. Similarly, lapses in a plan of care (POC) can be avoided by carefully managing re-evaluation dates. Make it standard clinic procedure for therapists to complete reevaluations as early as possible (30 days prior to the end of the existing plan of care) in order to allow for ample time to have the new POC signed by the physician and approved by an insurance company. The procedures you decide upon should be detailed in written form and agreed upon by each new hire so that you have a record of each person’s intent to follow them.
In addition, our recommendation is to create a comprehensive document for your clinic (called something like “Credentialing Guidance”) that outlines exactly which tasks are necessary to keep up with requirements for each insurance company. In this document (two documents, if you consider the provider version and admin version), it’s best to discuss how to go about a quarterly review process and keep a log of revision history (names and dates of anyone who has accessed and modified the document). Having a credentialing guide set up like this is invaluable if you have one or more admins working for you. Bringing on new staff is much simpler for everyone when exact instructions are available for reference.
Keeping these types of written, detailed documents will ensure that your business maintains continuity and resilience. Not only is it easier to run your business when you have regular systems in place, but the effect trickles down to your therapists and patients. There should never be an opportunity for your staff to question how you operate or wonder why their credentials have not been kept up. Because you’ll have a smooth process for credentialing, your patients won’t experience gaps in treatment. No gaps in treatment means a steady reliable plan for continuity of care for the patient, and revenue for the owner.
One area that is particularly challenging for clinic owners to navigate is the management and responsibility of CAQH accounts. Communicate Credentialing Guidance by setting expectations with your providers on how you want them updating their CAQH, and what data they may want to input. For example, the Primary Credentialing Contact on your providers CAQH account is moving to the forefront with several insurance companies (like Sunshine Health) in that their communication with providers will be performed via the Primary Credentialing Contact on file with the CAQH account. As a clinic owner, it is not good if a providers Primary Credentialing Contact points to an unmonitored or bad email address. As a provider its even worse- they may start rejecting claims. One big tip we can give is to communicate with your providers on the importance of attesting their CAQH accounts on a regular basis (for example: always discussing re-attestation dates in your townhall meetings).
A newer credentialing requirement is the attestation by the owner that they (clinic owner/business and employees/contractors) are using HIPAA compliant platforms. This is a big catch-all but the most readily apparent is/are your social media channel(s). The most egregious violation of HIPAA compliance is taking your most public communications channel (Facebook, Instagram, etc.,) and publishing your patient identities, development delays or DX and based on what we see, most clinics who publish to social media are doing it wrong. From the beginning (ie. starting your clinic ) if you are choosing to publish content on social media do it right. Consult with a professional on how to do it. We are not in a position to offer advice or guidance on HIPAA compliance and social media guidance we did find some useful information on the subject here Part 1: Social Media Guidance For Clinic Owners.
If you’re overwhelmed by these suggestions or unsure of how to implement them in your clinic, we’re here to help. Our two-plus decades of experience with the frustration of communicating with insurance companies serves as the fuel for making things easy for you and everyone affected by your clinic’s policies. Check out our Services and Solutions for more information.
Contact us now to see how our experts can assist you in transforming the day-to-day operations of your therapy clinic.
