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The OIG’S Compliance Program
Use
of a step-by-step implementation approach is strongly recommended, both by the
OIG, to ensure compliance with federal rules and regulations, and to establish
an environment of proper conduct and compliance within your practice. Below is
a summary of the OIG’s 7-step compliance program guidelines:
Auditing and Monitoring.
Physician practices should establish an ongoing evaluation process to
monitor both appropriateness of practice standards and procedures, and whether
standards and procedures are followed by physicians and staff.
When conducting an internal audit, both a standards and procedures
review and a claims submission audit should be performed.
Establish Practice Standards and Procedures.
After the internal audit identifies the practice's risk areas, the next
step is to develop a method for dealing with those risk areas through the
practice's standards and procedures. Written standards and procedures are a
central component of any compliance
program.
Designation of a Compliance Officer/Contact(s).
After an initial audit is
performed and higher risk areas are identified, a member of the
physician practice staff should be identified to accept
the responsibility of developing a corrective action plan and oversee the
compliance activities. This can
also be an outside consultant shared by several practices.
Conducting Appropriate Training and Education.
Education is an important part of any compliance
program. Education programs should
be tailored to your practice's needs, specialty and size and should include
both general compliance
and procedure-specific training.
Responding To Detected Offenses and Developing Corrective Action Initiatives.
If your practice detects a possible violation, a corrective action plan
needs to be developed to appropriately respond to the problem. If noncompliance
is suspected, your compliance
officer needs to investigate the allegations and ensure corrective and/or
disciplinary action is taken.
Developing Open Lines of Communication.
Physician practices need to have
open lines of communication to prevent problems from occurring and to
facilitate discussion of the reasons that problems occurred. Implementation of
a clear open door policy among physicians and compliance personnel is one way
to insure open communication.
Enforcing Disciplinary Standards Through Well-Publicized Guidelines.
The last step that your practice
may wish to take is to incorporate measures into its practice to ensure that
employees understand the consequences of non-compliance.
An effective physician
practice compliance program
includes procedures for enforcing and disciplining individuals who violate the
practice's compliance
or other practice standards.
The
Allcroft Group has expertise in the development of compliance programs in the
physician practice setting and can advise your practice in building such a
program. For more information,
please contact our corporate offices.
Source:
Federal Register, September 25,2000
(Summary available at:
http://www.hhs.gov/progorg/oig/modcomp/)
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