The Seven Components for an Effective Compliance Program

We all know that in 2010 the Affordable Care Act was passed by Congress. That’s the easy button! But, did you know that as part of the Affordable Care Act, any provider who treats Medicare and Medicaid beneficiaries is required to establish a compliance program?

So, what does this mean for the provider and for facilities to comply with this requirement?

The OIG has documented seven components to help provide a solid basis to which a practice or a facility can create a voluntary compliance program.

1. conduct internal monitoring and auditing

This is a good start; you can train someone in house or hire an outside organization to perform the audits

2. Implement compliance and practice standards.

Put your policies in writing and establish procedures for your organization to adhere to your compliance policies.

3. Designate a compliance officer or contact.

Assign or hire a compliance officer. This person will create, monitor and audit your policies.

4. Conduct appropriate training and education.

Educate, educate, educate! Here is the opportunity to provide education on your policies and procedures. Additionally, be sure to provide feedback to coders and clinicians specifically. In my experience they really want to learn.

5. Respond appropriately to detected offenses and develop corrective action.

Always respond to any error found and have a corrective action plan.

6. Develop open lines of communication with employees.

Communication is very essential. Coders and providers will not know they are making errors until you tell them.

7. Enforce disciplinary standards through well-publicized guidelines.

Enforce your policies and procedure! Make sure you have published and trained everyone about your compliance program. Everyone in the organization needs to understand how important it is, where to locate polices and procedure documentation, who to escalate issues to and/or how to report any violations.

The OIG is aware that full implementation of all these components may not be feasible for all practices and facilities. However, as a first step you can begin by adopting those components based on history with billing issues or other compliance issues.

There are products that are available for your organization to purchase to help with auditing and compliance. MRS has one that can help you get started. Check out www.mrsauditq.com and contact me for more information: robin@mrsnh.com.

For more information on the seven elements from the OIG, here’s a good summary resource: https://oig.hhs.gov/compliance/provider-compliance-training/files/compliance101tips508.pdf