Wiki Compliance Plan

[dballard2004]

Quick question....

I just took over as the coder/biller for a rheumatology practice with no written compliance plan Am I correct that per the ACA we need to have one in place? Can anyone point me in the right direction to start one? Hope this is not a foolish question but I just can't believe they never had one in place!

 

[JenniferB7]

You are correct. Offices are required to have a compliance plan, though it is unclear of the actual "effective date" of the requirement.

There are some great resources on the OIG website: https://oig.hhs.gov/compliance/101/index.asp

If you PM me your email address, I can email you a plan template.

Jennifer M. Connell, CPPM, CPCO, CPMA, CPB, CPC, CPC-I, CPC-P, CENTC

 

[CatchTheWind]

My doctors would like to see CMS's statement that compliance plans are now required, not just recommended. Does anyone have a link to such a statement?

Thanks!

 

[Chelle-Lynn]

Section 6401 of the Affordable Care Act provides that a "provider of medical or other items or services or supplier within a particular industry sector or category" shall establish a compliance program as a condition of enrollment in Medicare, Medicaid, or the Children’s Health Insurance Program (CHIP). The Affordable Care Act further required the Secretary of Health and Human Services (HHS), in consultation with the HHS Office of Inspector General (OIG), to establish "core elements" for provider and supplier compliance programs within a particular industry or sector.

In doing so, HHS has the discretion to determine both the timeline for implementation of the core elements and the requirement to have a compliance program. An enforcement date for provider compliance plans as mandated in the Affordable Care Act is yet to be issued. But since the late 1990s, long before the Affordable Care Act legislation mandated that providers put a compliance plan in place, the Office of Inspector General (OIG) began a major initiative to support Health care Professions in establishing a compliance program for their offices, organizations and practices.