Also, your compliance officer or contact person should have an open-door policy for all employees. They need to know they can report any compliance issues they detect. This is important: If an employee believes they cannot discuss any concerns they have in the office, then they may prematurely report an issue to the OIG, which can threaten a provider’s reputation and expose the practice to potential audits.
Enforce Disciplinary Standards through Well-publicized Guidelines
Lastly, an effective compliance program/plan includes procedures for enforcing and disciplining employees who violate the office policies. Adding provisions for enforcement and discipline in your compliance plan will add validity and credibility to the office compliance program/plan. The compliance plan should be easy to read and accessible to all staff. The compliance officer, along with the provider(s) and key staff, should review, revise and approve the compliance plan each year. Also, it may be judicious to have your employees review and sign the revised plan each year, because this will signify that they understand the policies and updates set forth in the plan.
The OIG acknowledges that patient care is, and should be, the first priority of a physician practice. The incorporation of a compliance plan is not designed to take that away. It is intended to help your practice maintain quality patient care through increased accuracy of documentation; this will minimize coding and billing errors and optimize proper payments of claims. Implementing a well-designed compliance plan can reduce the risk of an audit by the OIG, Medicare or other private payers, as well as avoid any conflicts with the self-referral and antikickback statutes.
A compliance program will send an important message to employees that although the practice recognizes that mistakes will occur, employees have an ethical duty to report any errors so they may be corrected and the practice can work to avoid other errors.
Keep in mind that no formal date has been set by the OIG to apply consequences if a practice does not have a compliance plan; however, now is the time for physicians and their staff to design a personalized plan. It is imperative to be proactive rather than reactive to stay in line with the OIG’s fundamental elements of a compliance program.
If you are seeking to revise your current compliance plan or need assistance in developing a plan for your practice, the ACR practice management department is here to help. Contact Antanya Chung at [email protected] or 404-633-3777 x818 with any questions.
