Many if not all employees will have some compliance-related responsibilities. Depending on these individual responsibilities, include them in the employee’s job description as an element of that job. For instance, billers and coders might have a task in their job description that requires them to correctly use current CPT and ICD-9 books to check their coding. Supervisors might have a task requiring them to monitor the billing and coding compliance activities of their subordinates. These tasks should mirror the compliance procedures that the employee is expected to follow. Additionally, annual and periodic performance appraisals should rate each employee on the compliance elements in their job description. Compliance officers should use this aggregate performance data as one measure of the effectiveness of their compliance program.
