Deciphering the "Black Box": Compliance and the Operating Room, Part II

To most observers outside of the operating room, the delivery of surgical care seems very straightforward. In contrast, special and unique compliance issues arise in the operating rooms of academic health centers and teaching hospitals, which are governed by Chapter 12 of the Physician Teaching Rules of the Medicare Claims Processing Manual. Overlapping procedures can be a distinct challenge for the compliance professional without adequate policies and procedures in place to appropriately account for the activities and involvement of the teaching surgeon and his or her fellows and residents. Compliance with the billing requirements for overlapping surgery relies heavily on the documentation of the teaching surgeon. Compliance professionals working in an academic health center or teaching hospital setting first should begin reviewing documentation requirements for their facility with regard to performing overlapping surgical procedures. Specifically, they should determine if the overlapping surgery policies and procedures are sufficient to facilitate compliance at their respective institutions.