« Notices of privacy practices | Main | Documenting E/M services »

June 11, 2009

How to handle penalties against non-compliant partners

You cannot effectively impose penalties against non-compliant partners without clear provisions for punitive action. Our experts, thus, urge providing for sanctions, and specifically for monetary penalties, within your group documents.

Ask your attorney if your present contracts permit assessing penalties for non-compliant behavior. If they do, undertake partner-level adoption of a specific penalty system. Among other reasons, just doing so (and following it whenever necessary) helps prove the group's intent to carry out an effective Medicare compliance program, possibly mitigating any fines in case of audit.

These days, effective groups' documents should specifically address performance expectations and permit penalizing for failure to meet them. You are better served to improve your legal structure before a problem arises than to find yourself hamstrung when you need to act.

TrackBack

TrackBack URL for this entry:
http://www.typepad.com/services/trackback/6a00d83451b7e869e2011570f4c087970b

Listed below are links to weblogs that reference How to handle penalties against non-compliant partners :

Comments

Verify your Comment

Previewing your Comment

This is only a preview. Your comment has not yet been posted.

Working...
Your comment could not be posted. Error type:
Your comment has been saved. Comments are moderated and will not appear until approved by the author. Post another comment

The letters and numbers you entered did not match the image. Please try again.

As a final step before posting your comment, enter the letters and numbers you see in the image below. This prevents automated programs from posting comments.

Having trouble reading this image? View an alternate.

Working...

Post a comment

Comments are moderated, and will not appear until the author has approved them.