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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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