Written by Bev Jenkin Tuesday, 14 September 2010 00:00

As a Human Resource Specialist (CPM-HRS), I am often asked about how a practice can safeguard itself from theft.  The one vein that runs consistent through every seminar/webinar/lecture I attend on the subject is taht you cn never let your guard down and you can never completely control the actions of others.  What you can do is keep your eyes and ears open, take as many of the necessary steps as possible to prevent theft/fraud, and protect yourself and your practice.

The ACFE (Association of Certified Fraud Examiners) has just published their June 2010 Report to the Nation.  The ACFE is the world's most quoted and authoritative organization on fraud, serving 140 countries, and publishing this report every two years.  Currently there are 50,000 CFE's (Certified Fraud Examiner) in this organization, up from 25,000 in 2002.  According to this report, the amount of loss associated to fraud is 2.5 times higher than it was in the year 2006, and healthcare has been one of the top five industries effected, out of the twenty-two industries represented, for the past four years, with a median loss of $160,000.

The average amount of time it took to uncover fraudulent activity was 1.5 years and in over 48% of all cases it was caught because of an accidental tip from an employee, customer, or vendor.

Three primary fraud schemes that were prevalent in effecting and impacting the healthcare industry were:

• Corruption
• Skimming cash, and
• Falsely billing

Although you can never be completely protected, below is a partial list of actions HIC recommends be taken:

• Background investigations, including credit checks, have to be conducted
• References must be checked, healthcare is a big business - but a small world where someone knows someone who worked in someone else's office
• Antifraud training must be provided and a written manual must be in place with signed acknowledgements
• Mini-performance evaluations should be conducted quarterly with a full scale evaluation being performed one time per year
• Make sure every staff member takes time off (PTO/Vacation/etc) and someone else fills in for their duties while they are gone
• Do not allow clerks to run returns on credit cards
• Be sure there is a sale to match every return on a credit card statement
• Don't overlook the small amounts, there are more likely to be money taken as most people feel that small amounts won't be readily noticed
• Do not allow the person who inputs the charges and credits to be the same person who balances the day end accounting
• Be sure not to ask patients for information you are prohibited from asking for (i.e. social security numbers)
• Cross-train the staff on the accounting software your office uses
• Have an outside accounting firm perform quarterly audits
• Have a strict cell phone policy and do not allow cell phones, or any devices with cameras to be utilized in the office
• Set policies with regard to the proper storing and shredding of any identifying or confidential paperwork
• An anonymous Compliance Office "Tip Box" or "Tip Line" should be set up
• Bond your practice administrator and any other employees who have access to large amounts of the company's funds
• Do not allow corporate checks to be "signature stamped"
• Enforce a no repercussion whistleblower policy
• Conduct exit interviews

It is critical to have a good check and balance system.  The honest employee wants this for their safety as much as yours.

Remember that fines for as much as $10,000 have been assessed against physicians for data breaches if their office staff is found to be responsible for the infraction.