Compliance Plans
We have all heard of Compliance Plans. Many practices have a “cookie cutter” compliance plan—purchased, downloaded, or copied from another practice. There are also companies that offer standardized or generic compliance plans. Although it may seem the easiest way to be “compliant, if your compliance plan is not personalized for your practice, you could face scrutiny from the OIG.
Organizing, implementing, and maintaining your compliance plan is one of those projects that we all plan to get to but never seem to have enough time for, since our efforts are focused on the day-to-day running of a medical practice. Or, if you are a physician, you’re focused on seeing and taking care of your patients.
The Affordable Care Act requires that the U.S. Department of Health and the OIG publish regulations that require most healthcare providers and durable medical equipment suppliers to establish compliance programs. In 2018, compliance plans were no longer optional, as they had been for many years. That year, CMS finalized the requirements for provider compliance plans; the implementation of a compliance plan is now required to participate in Medicare and Medicaid.
The OIG has identified seven elements of a compliance plan:
Standards, Policies and Procedures
Compliance Program Administration
Screening and Evaluation of Employees, Physicians, Vendors, and Other Agents
Communication, Education and Training on Compliance Issues
Monitoring, Auditing and Internal Reporting Systems
Discipline for Non-compliance
Investigations and Remedial Measures
Compliance plans do not come “one size fits all.” A compliance plan that makes sense for a large practice with multiple providers and employees may not make sense for a one-or two-provider practice with a few employees. Finding or crafting a “right-sized” compliance plan is key! Once you have found a compliance plan that works for your practice, don’t just put it on a shelf to gather dust. You must review, update and maintain your compliance plan on a regular basis to reflect that compliance is a priority to your practice, identify potential fraud and abuse risk areas within your practice and manage all financial relationships.
Let PMRG be your partner in compliance. If you need assistance reviewing or updating your compliance plan, don’t hesitate to contact me at jholt@medicalpmrg.com.