Class 10 – COMPLIANCE PLANS


Many Consultants are telling Physicians to protect themselves in terms of compliance plan issues:

  • Delegate responsibilities wisely and be proactive – review regularly
  • Implement Compliance Program – Beef Up Internal Controls
  • Get involved – follow, be involved with new legislation

The Office of Inspector General of the Department of Health and Human Services has issued a model compliance plan for clinical laboratories and hospitals. Typically, compliance plans include the following

Written policy setting forth the provider’s commitment to accurate coding and billing for all of its services.Distribute the policy at least annually to finance personnel, billing clerks, physicians, and anyone connected with the provider’s billing function.

Orientation program for finance personnel, billing clerks, medical record personnel, physicians, and anyone else involved in the processing or submission of claims for reimbursement. This program should include not only proper procedures for medical record-keeping, coding and claims preparation and submission, but also a discussion of the criminal and civil penalties for submitting false claims.

Implement audit procedures and internal billing controls to detect billing inaccuracies as quickly as possible. This would include a broad range of sampling and audit of frequent billings of specific procedure codes.

Appoint a chief compliance officer or assign senior management to oversee compliance standards and procedures.

Compliance plans would also include:

Establish a disciplinary process to enforce standards and procedures covering both those responsible for improper practice and those who had the responsibility and failed to detect the offense.

Create an internal “whistle-blower” system in which employees can alert the chief compliance officer or another member of the provider’s senior management about suspect billing practices or improper referral arrangements without fear of reprisal. This includes a reward program for such information.

A compliance plan must be active and ongoing.  It is better to have no compliance plan than an ineffective plan.

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