Happy 2024 to all! Wishing you a happy, healthy and successful upcoming year.
As I think about the road ahead, Compliance is the #1 topic that comes to my mind. It is top of mind because, in 2023, I was gobsmacked by the number of instances of compliance issues we consulted on or were privy to. Everything from HIPAA breaches to billing fraud and ChatGPT erroneous citations – whether due to conscious behavior or naivete, each was a compliance issue nonetheless.
What is disconcerting is how many owners and BCBAs were engaging in these behaviors because they were taught that way by their prior employer(s). I recently had a client owner who knowingly had BCBAs changing the dates of service for supervision to avoid the issue of concurrent billing. When asked about it, the response was “I’ve worked for large companies and small companies, and they all did it, so I didn’t know it was a problem.” Well, when a $1mm recoupment comes your way, that will be the very unfortunate and hard way to learn what is billing compliant and what is not.
It shocks me that I still know of companies where RBTs are 1099’s. There is frankly no excuse for a business owner to not know federal law when it comes to 1099s vs. W2 employees and who qualifies and who doesn’t. Sadly, because these companies operate this way, BCBAs unknowingly think when they launch their own business that this is OK and so the cycle continues.
Another example is newly hired BCBAs conducting services that are billed to insurance before they are credentialed with the payor. Time and time again we consult on how to best utilize a BCBA between the time they are hired until they are credentialed, which typically takes 30-90 days. I understand it is a hard pill to swallow to pay a BCBA salary when you can’t bill for the work they performed, but frankly, that is the cost of doing business in a compliant manner. So, I leave you with some best practices with respect to how to best utilize your new hire BCBAs until they are credentialed.
- Ideally, provide the BCBA you intend to hire an offer letter with a future start date of at least 30 days. This allows the BCBA to provide one month’s notice to their current employer which is the BACB’s ethical recommendation to ensure streamlined transition of services for clients. This allows you, the new employer, a 30-day jump start on the credentialing process thereby reducing the number of days your new BCBA will be a part of your team but not yet billable.
- Have the BCBA provide new hire or ongoing training for your techs and RBTs. What better way to ensure your therapists are well-trained and to assess your BCBA’s knowledge and skills, than to see them in action?
- Have the BCBA provide direct service for clients who are not receiving their authorized hours or have cancellations where otherwise the session would not occur.
- Learn your practice management system. Oftentimes BCBAs come having used a different PMS/data collection system and need time to learn how to maneuver in the new system so they are well equipped to support their clients and BTs as they grow their caseload.
- Shadow the clients that are transitioning to them.
- Learn your policies, procedures, and operations. In every company, there are formalized (or not formalized but known) P&Ps that are unique to your company.
- Get to know your Vision, Mission, and Values and how they drive your daily work. BCBAs join from other places with different ways of doing things. Help them fit into your team by showing them how you do things, why it matters, and how to embrace your vision, mission, and values in their day-to-day work life.
CONTACT US today for compliance assistance. You don’t want to learn the hard way.
