Medicare Compliance & Reimbursement

OIG considers adding eighth core compliance element to existing seven.

Compliance program guidance (CPG) currently in the works at the HHS Office of Inspector General could add a new component to the feds' fundamental expectations for health care providers' compliance plans.

In a Sept. 5 Federal Register notice, the OIG says it's launching work on a new CPG for recipients of research grants from the National Institutes of Health. The agency points out that most colleges, universities and other grant recipients are non-profits - and that in recent years more than half have been medical schools, already familiar with compliance through the programs they've instituted in their hospitals. The agency asks that interested parties submit comments on how the CPG should be tailored to the research grant context.

But the big news for providers across the board is the OIG's suggestion that it might add an eighth core compliance element to the seven elements that formed the basis of its 11 previous compliance guidances. The newly proposed component  is: "Defining roles and responsibilities and assigning oversight responsibility." It supplements the familiar seven, which include establishing written policies and procedures, designating a compliance officer, developing internal lines of communication and conducting internal monitoring.

To see the notice, go to http://www.access.gpo.gov/su_docs/fedreg/a030905c.html.

Lesson Learned: Effective delegation may become a key compliance expectation as the OIG's - and the provider community's - thinking on corporate integrity continues to evolve.