Tips to help you develop or update a compliance plan.
In 2000, the Office of the Inspector General (OIG) published guidelines for compliance plans for physicians. The regulation pertains to all physician groups, regardless of the size of the compliance plan.
Do you know where to locate a copy of your office’s compliance plan? Hopefully, you do. But, even in the best managed practices, you may still need to dust it off and look inside. Should you find doing so a little scary, there is cause for concern, but not alarm. Developing or updating a compliance plan is not difficult to do if you follow these six tips.
Organizing practice goals and objectives makes the task of writing or rewriting a compliance plan easier. The practice must have a designated compliance officer who reviews, revises, and carries out the compliance program for the practice. In small groups, the compliance officer is frequently the office manager or the administrator. The compliance officer is the compliance committee chair and is responsible for scheduling meetings or calling a special meeting if an issue arises.
An effective compliance committee must be updated consistently. When the compliance committee is comprised of employees and physicians who represent different specialties or areas in the practice (billing, front desk, a technician or scheduler, etc.), the plan is more applicable and easier to understand and follow. When a compliance plan “gathers dust” and is not regularly reviewed, it quickly becomes outdated.
Just as each practice is unique, so are compliance plans. Your plan should “fit” the services provided by the group. When a committee of diverse individuals develops a plan, it can easily be customized to represent the actual work inside the practice. Be sure to capture any changes in specialties, as this may impact billing and coding protocols.
A well-organized and carefully developed plan focuses on areas where compliance is non-negotiable. For example, when a misguided provider or employee intentionally submits a claim to the patient’s insurance or Medicare to obtain higher payment, this is wrong and, if discovered, will likely result in criminal charges. Educate providers and staff about high-risk areas, and clearly document a no-tolerance policy to provide leverage for managing issues should they arise.
Once developed, the compliance plan should be adopted as an official practice document by the physician owners or the board of directors. Also, have the attorney for the practice review the plan and advise on any needed changes.
A well-written compliance plan provides protection for everyone, and its importance should be recognized throughout the organization. Also, those who are vigilant with carrying out compliance should be recognized for their efforts.
Compliance is everyone’s responsibility. Any practice, regardless of size, must have a written compliance plan for documenting how the entity implements and complies with federal and state regulations/laws pertaining to medical practices.
Take time to review the your practice’s compliance plan today. OP