Impact of a compliance program for billing on internal medicine faculty's documentation practices and productivity

Academic health centers and faculty practice plans have implemented programs to comply with Office of Inspector General (OIG) billing regulations. This study measured the impact of such a program on physicians' billing practices, faculty productivity, and operating revenues.

A prospective two-year study of departmental billing activities was carried out in 1997-98 and 1998-99 in the department of internal medicine at the Saint Louis University School of Medicine and its faculty practice plan. Compliance with inpatient evaluation and management (E/M) coding and Health Care Financing Administration (HCFA) billing was evaluated by an independent staff of experts. Beginning in 1998-99, the department provided detailed monthly reports of and education in billing and compliance performance to divisional managers and individual faculty.

Inpatient admission profiles, practice patterns, and payer mixes of the faculty practice plan and department did not differ during the study. The gross collection rates for the practice and the department rose by 7.3% and 9.5%, respectively, and all divisions increased in their gross collection rates in 1998-99. All but one division increased E/M services in 1998-99 (range -4% to +151%). All divisions decreased their rates of unbillable E/M services in 1998-99. The two divisions with the highest unbillable rates in 1997-98 (gastroenterology and cardiology) significantly reduced their unbillable service rates in 1998-99 (-7.74% and -7.17%, respectively). Medical oncology and geriatrics recorded the greatest reductions in 1998-99 (-63% and -52%, respectively). All but two divisions increased the percentages of complex inpatient E/M services in 1998-99 (average = +27.4%), with commensurate reductions in less complex visits (p < 0.05), and there was an inverse correlation (R = -0.85; p < 0.01) between the relative increases in the division's inpatient encounters and the service complexity charged. A modest inverse correlation (R = -0.50; p < 0.05) existed between the reduction of relative percentages in divisions' unbillable rates (averaging -34%) and the increase in their gross collection rates (averaging + 31%).

Implementation of a billing compliance program at the departmental level enhances physician productivity and billing compliance for inpatient E/M services, potentially increasing departmental revenues while reducing the institutional risk of an OIG audit.