Have you started developing your compliance program yet? Do you have a compliance program that is incomplete or not as active as it should be?
The Health Care Reform Act and the Patient Protection and Affordable Care Act require a compliance program be implemented by 2013 for all health care providers and dental providers that bill Medicare and Medicaid or any federal and state funded programs. The OIG (Office of Inspector General) has had suggested compliance program guidance for several years for hospital, physicians, DME and home health. I would recommend health care providers start planning by using these OIG guidelines because it will take at least 9 months to have a program implemented completely. A compliance program will also help your business run more efficiently if the program is managed correctly.
Compliance programs focuses business operations & management, contracts, relationships, billing, and the laws associated with each. Two key components to ensure success for the program is executive support and employee participation. A compliance program is more than policies.
The elements of a compliance program include:
1. Compliance Officer, which may hold several positions in smaller agencies.
2. Compliance Committee, best to have managers or supervisors from various departments to be a solid advisory committee.
3. Standard of Conduct covers various topics from Stark Law, Antikickback statute, Company funds, Investigations & legal matters, billing expectations, complaint reporting, and much more.
4. Policies and Procedures expand some sections of the standards of conduct such as the billing section.
5. Training of at least 5 hours per year, in addition to the training for privacy and security annually.
6. Auditing and Monitoring help ensure the risk areas for the company and identified by the OIG stay within the regulations and coverage criteria, prevents fraud and abuse or at least early detection, and training to prevent the repeat of erroneous actions.
7. Hotline for reporting,even if it is a local phone number for small companies with 1 to 2 locations. Complaint reporting should not be limited to a hotline. Complaints should be allowed by email, mail, and fax as well. You need a hotline poster, but it does not have to be elaborate or expensive.
If you can you help with your compliance program, we have extensive experience in health care compliance program development and management.
Angela Miller of Medical Auditing Solutions LLC has been in health care compliance, auditing, billing, collections and HIPAA for over 18 years. Ms. Miller has made it the focus of the business to help providers run their businesses efficiently, collect money, and maintain compliance with federal and state regulations and coverage criteria through compliance program development, management and training. Ms. Miller is very experienced with Medicare & Payer audits. Ms. Miller ran a very successful compliance program for over 5 years for the largest private held HME/Pharmacy provider in the US at the time. Ms. Miller also works as a contract compliance officer to provide an avenue to compliance training to staff, implementation of policies, as well as handling anything that affects cash flow from the initial intake to back-end collections. You can visit our website at Medical Auditing Solutions LLC.
