Implement a Compliance Plan Before It's Too Late!

In order to assist health care providers to develop and carry out effective and meaningful compliance plans, the Office of Inspector General of the United States Department of Health and Human Services (OIG) issued a series of compliance program guidelines, which include certain basic elements: 1) Creating and implementing written policies, procedures and standards of conduct; 2) Designating a compliance officer and/or committee, depending on the size of the organization; 3) Training and educating staff and employees; 4) Creating effective lines of communication between staff and the compliance officials; 5) Enforcing standards through well-publicized disciplinary guidelines; 6) Taking part in internal monitoring and auditing; and 7) Making prompt responses to detected offenses and implementing meaningful corrective action. The OIG recognizes that physician practices face financial and staffing constraints and not all elements of the model program can be implemented.

Any effort to create an effective compliance plan will involve identifying the areas of risk. This often requires focusing on areas that have been problematic in the past, such as coding and billing. Reviewing the claims denial history or claims that have resulted in repeated overpayment would be a logical place to begin. Such an exercise not only helps the practice identify significant risk areas, but will also improve cash flow by increasing the number of claims that are paid the first time they are submitted.