Reed Tinsley, CPA

7 elements of an effective compliance plan

The Office of Inspector General (OIG) has recommended the following seven elements of an effective compliance plan. This applies to all healthcare entities. Although these elements are well known, how many of them are currently implemented within your physician medical practice?

- Designation of a chief compliance officer and implementation of a compliance committee;

- Implementation of compliance policies and procedures, including standards of conduct;

- Have open lines of communication;

- Conduct training and education:

- Respond to detected offenses;

- Implement internal monitoring and auditing; and

- Have enforcement and disciplinary standards.

HEAT Healthcare Toolkits Posted on OIG Website

The Healthcare Fraud Prevention and Enforcement Action Team (HEAT) and the Office of Inspector General have posted a Toolkit consisting of a series of podcast training videos on the following subjects:

• How to Use the Exclusions Database
• How to Report Fraud to the OIG
• OIG’s Self-Disclosure Protocol
• Tips for Implementing an Effective Compliance Program
• Compliance Program Basics
• Physician Self-Referral Law
• False Claims Act
• Federal Anti-Kickback Statute

For any size physician practice, you should view these training videos - compliance is a very HOT topic these days, not only on a Federal level but a State level as well.

http://oig.hhs.gov/newsroom/podcasts/index.asp

Physician compliance - a first step

Unfortunately, too many physicians are unconcerned about fraud and abuse. Most are confident that their practice operations are compliant with Medicare billing and documentation guidelines, and that they would never intentionally defraud anyone. True or not, this laissez faire attitude and false sense of security has the potential to hurt physicians financially and professionally by not allowing doctors to focus on the life-blood of their practice - documentation, coding and billing.

So as a first step, perform a Practice Analysis to provide ‘baseline’ statistics and develop a “snap-shot” of the practice’s current operations relative to reimbursement, compliance and operations. This involves a detailed review of all CPT/HCPCS codes and productivity reports for coding compatibility, unrepresented services and baseline statistics, and a detailed comparison of each physicians’ E/M service utilization to specialty-specific Medicare E/M data to identify under or over utilization of level of service codes. The initial results of the analysis are then linked to diagnostic coding and documentation compliance to enhance revenues while reducing post-payment demands from Medicare, Medicaid, etc.