What is a compliance plan?
A compliance plan is a collection of steps that a provider, organization, or practice establishes to ensure adherence to federal and state regulations. OIG developed voluntary compliance program guidance in an effort to help organizations with their compliance programs. Resources can be found at www.oig.hhs.gov. These resources assist in setting the foundation to an effective program.
In 2003, OIG developed Compliance Program Guidance for Pharmaceutical Manufacturers. In this document, there were seven elements for an effective compliance program. Although the document was directed towards pharmaceutical manufacturers, the elements can be used as the framework for any specialty. The elements include:
An effective and successful compliance plan should outline each of these seven elements and include directions, standards, and policies for how each element will be handled.
If an area of non-compliance is found, detailed records of the incident or misconduct should be documented with the date, name of the person that reported the issue, the person who initiated action on the issue, and any corrective or follow-up action that was taken.
The Federal Register Vol. 65 No. 194, published on October 5th, 2000, outlined Compliance Program Guidance for Individuals and Small Group Physician Practices. This document can be found at www.oig.hhs.gov. This document details the risks and benefits to a compliance program.
Some of the possible risk areas for physicians and physician practices include documentation, federal regulations noncompliance, coding and billing issues, and medical necessity issues.
Below are a few points from each category:
Compliance Program Benefits
Compliance programs and plans have many benefits if they are implemented and adhered to in a consistent manner. An organization that is aware of their compliance plan usually finds fewer billing and coding mistakes, their documentation accuracy improves, and their chances for a government audit decreases.
Ensure that compliance plans address the issues specific to the organization or provider. No two compliance plans will be alike since they should be tailored to the individual provider, practice, or organization. Make sure that auditing is a major part of the compliance plan and that an auditor can review an organization’s compliance plan. Furthermore, provider education should incorporate issues set forth in the compliance plan.
Tip: OIG developed CPGS for many healthcare entities!
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