Neurology & Pain Management Coding Alert

Compliance plans have become standard fare for many physician practices, but that doesn’t mean you should write it, put it in a binder, and never look at it again. Here’s a refresher on what you should include to create a compliance plan that meets your practice’s needs and will help protect you from potential accusations someday. 

 

 

The OIG (Office of Inspector General) outlines seven components that your compliance plan should include -- and offers special guidance for hospitals, third-party billing companies, and small private practices (you can access this information online at oig.hhs.gov/compliance/compliance-guidance/index.asp).

 

 

1. Conduct internal monitoring and auditing.

2. Implement compliance and practice standards.

3. Designate a compliance officer or contact.

4. Conduct appropriate training and education.

5. Respond appropriately to detected offenses and develop corrective action.

6. Develop open lines of communication.

7. Enforce disciplinary standards through well-publicized guidelines.

 

Resources: You might enlist the help of your practice’s health care attorney at some point while drafting your compliance plan. Getting a legal expert’s input and final approval will ensure you haven’t overlooked any important elements -- and will bolster your plan’s legitimacy. 

 

In addition, you can hire a healthcare management consulting firm specializing in compliance plans to write your entire compliance plan or to offer legal advice. The more specialized your practice is and the more ancillary services you offer, the more help you’re likely to need to make sure your compliance plan covers all your liability areas. 

 

If your practice belongs to a healthcare specialty society, this may be an excellent resource to tap into. Societies may have customized templates and other data useful for creating a specialty-specific compliance plan.

 

 

At all costs, you should avoid downloading or purchasing a cookie-cutter compliance plan that only requires you to fill in the blanks with a few practice details. If your compliance plan isn’t customized to address the unique details of your office’s billing practices, the document will not be a useful source of guidance for billers and physicians. A cookie-cutter plan quickly purchased and stuffed on the shelf won’t help you prove your commitment to compliance. 

 

Why it matters: Compliance requirements associated with the Affordable Care Act (ACA) will address your Medicare patients, but don’t forget Medicaid.  

 

“State Medicaid plans must require providers and suppliers to establish a compliance program that contains the same core elements that HHS, in consultation with HHS-OIG, eventually will establish with respect to the Medicare program,” says Scott A. Memmott, Esq., with Morgan, Lewis & Bockius, LLP, in Washington, DC. Therefore, even doctors who see no Medicare patients but do see Medicaid patients will be subject to mandatory compliance program requirements that will come from their state Medicaid plan, he adds.