To be sure your providers and employees are following all rules and regulations to keep your medical practice compliant, you should create a compliance program. The Office of Inspector General lists seven core components for an effective compliance program.
- Implement standards through written policies and procedures
Providers and employees need written policies or procedures to know what is expected, what rules are out there, and how these are to be followed.
- Designate a compliance officer and committee
Employees will need to know who to turn to with questions or concerns. That person is a designated Compliance Officer, who will be a direct link to a Board, CEO, or Upper Management. If possible, you also should select a committee to work with the Compliance Officer. The committee helps in the decision process, collectively creating written policies and procedures, and provides the tools for education and training. The officer and committee are also responsible to provide a process in which an employee may report any concerns regarding fraud, waste, or abuse.
- Develop effective lines of communication
Provide a tool for physicians and staff to voice their concerns regarding fraudulent behavior, and state consequences for noncompliant behavior. Make it easy. Include in your compliance training where an incident report is accessible to all clinic employees. Create a process to send the incident report anonymously or electronically to your Compliance Officer, or to a member on the compliance committee.
- Conduct a system for monitoring, auditing, and identifying risk
Use your findings to develop policies, procedures, and education and training, and as a basis for future audits. Keep current with all rules and regulations of the payers for which your office or clinic works, and follow the guidelines provided by the Office of Inspector General.
- Create a process for reporting issues and prompt responses
Create an easy process not only for reporting, but to do so anonymously. Encourage all employees by giving them a voice. Provide a slot box or create an incident form where employees may send the form electronically with a “no name” email address to remain anonymous, if they so choose.
- Conduct effective training and education
Create benchmarks to determine if the education and or training were effective. Follow through with corrective action needed to follow the specific rules and regulations set forth by the payers for which claims are filed for payment of services.
- Enforce disciplinary standards through publicized guidelines
Provide written guidelines for discipline. Let the employees know what actions may be imposed for noncompliant behavior or actions. Be sure to outline the consequences of noncompliance, such as retraining, verbal or written reprimand, warnings, probation, and, lastly, termination of employment.