Compliance plans are useful and serve a purpose. The primary reason you need a compliance plan is to prevent mistakes from happening. It’s nothing more than guidelines for your staff to follow to ensure that everyone abides by existing laws and regulations. Aside from the fact that current guidelines require all providers to have a compliance plan, the self monitoring instigated by having a compliance plan helps prevent errors—and that can help prevent government audits. And we want to prevent government audits because they are usually time consuming and expensive.
Let’s face it, talking about compliance isn’t exactly a barrel of monkeys. There isn’t a doctor’s office that I know that enjoys talking about compliance. But it’s necessary to at least address the issue in this day of regulation and investigation. To ease the way, the Office of Inspector General (OIG) through the Health Care Fraud Prevention and Enforcement Action Team (HEAT) has provided a series of training videos for use by physicians to help navigate the way through developing and implementing a compliance program for your practice. These podcasts introduce the basic reasoning behind compliance issues as seen through the eyes of the OIG. The videos, available at http://www.oig.hhs.gov/newsroom/video/2011/heat_modules.asp will help you understand the basic components of a compliance plan. Topics range from the Importance of Documentation to details about the False Claims Act (a mistake is not fraud!) to the OIG’s Self Disclosure Protocol. The videos average 3 to 5 minutes, so it’s easy to fit them in on a break or at lunch time.
Developing and implementing a compliance program will in turn help reduce unintentional fraud, and having one in place can eliminate or reduce penalties should you ever be the target of an inquiry. The podcasts provide a decent starting point, and even tell how to determine that your employees are not excluded from being eligible to perform their functions in your practice. (You can check the OIG exclusions database here: http://exclusions.oig.hhs.gov/.)
Guidance provided in the podcasts is general in nature. The OIG has not issued a model compliance plan because everyone’s plan would be different: A doctor’s office requires a different plan than a lab, nursing facility, hospital, billing company, or DME supply company. Although it may seem like you’re on your own when it comes time to create and implement a plan, you’re not. You can buy a plan tailored to your sector of the healthcare industry, or you can create your own with the help of a healthcare attorney, billing company, or trade association like the AMA, MGMA, or others like them. Creating and implementing a compliance plan is a long term project that can take up to a year to complete. If you want to start from scratch, these podcasts will provide you with enough guidance to find your jumping off point.
We recommend that every physician or practice administrator take the time to look at these podcasts. Watching them may motivate you toward creating or improving your own compliance plan. Again—having a compliance program in place is not optional. The sooner you have one, the better.
Here at Medical Billing Resources, we advise all our clients in creating, implementing, and updating their compliance programs. Although creating a compliance plan is a daunting task, it’s a lot less so than going through a government audit unnecessarily. It’s better to be able to say “my compliance plan helped us prevent a mistake,” rather than “a compliance plan could have prevented this mess.”
For some beginning guidelines to help you get started on writing your compliance plan, also see our blog post, entitled, Elements of a Medical Office Compliance Plan. Please feel free to write or call with questions about how to get started on creating your own medical office compliance plan: 800-895-9563.
