Don't stop with the OIG guidance. Crafting or updating your hospice's compliance plan can seem like an overwhelming task, but you have lots of help if you know where to look. The first stop for your compliance plan research should be the HHS Office of Inspector General's compliance guidance at www.oig.hhs.gov/fraud/complianceguidance.asp. The OIG issued model compliance programs for home health agencies in 1998 and hospices and durable medical equipment suppliers in 1999. But don't assume you can download the guidance and call yourself done. "The Compliance Program Guidances are merely guidelines," warns attorney Julie Mitchell with Copeland Cook Taylor & Bush in Ridgeland, Miss. "Providers should adapt those guidelines to their particular size, type, and issues," Mitchell tells Eli. "So much has changed since then," points out attorney Liz Pearson with Pearson & Bernard in Edgewood, Ky. of the late '90s issuances. A risk analysis of your organization should show where you should focus your compliance plan resources, suggests attorney Robert Markette Jr. with Gilliland & Markette in Indianapolis. Other important resources for crafting or revising your compliance plan include: Your own existing P&Ps. "Most agencies have policies and procedures in place that address compliance, but they are scattered about in clinical policies, billing policies, etc.," Pearson notes. "The compliance process does not require recreating the wheel," she says. You can gather the P&Ps together to help form your plan. Don't forget: "But each policy should be reviewed and monitored to see if it hits the target to address all compliance issues," Pearson says.