It is still evident to me that too many physician practices still do not have effective fraud and abuse compliance programs integrated into their practices. To date there has been no federal or state mandate that physicians implement a compliance program but such a mandate is coming. In fact, the Affordable Care Act of 2010 charges the Secretary of HHS in conjunction with the Office of Inspector General with implementing mandatory compliance programs for Medicare providers. However, as I have said previously on this blog, you shouldn't wait until it's a requirement. An effective compliance program offers practice many benefits including early identification problematic billing and contractual arrangements and potential mitigation of penalties in any fraud and abuse settlement or prosecution. Frankly, in this highly regulated environment, having an effective compliance program is simply good business. There are many excellent resources on building an effective compliance program. Most medical associations and specialty societies have developed resources on the subject. Without question, however, the starting point should be the compliance program guidance published by the OIG itself since this identifies those elements of a program that the OIG deems to be or most importance. For more information on building an effective compliance program on a budget, see Medicare Fraud and Abuse and Your Practice and Compliance Planning on a Shoestring Budget.
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