Virtual Compliance Office
Physician Compliance Plan
Healthcare providers can take two steps to initially address compliance in their organization. The first is the performance of a benchmark compliance audit either internally or by outside consultants or auditors. A thorough benchmark assessment can detect if there are any compliance concerns including the lack of proper documentation in the medical record, the use of incorrect CPT coding assignments, issues with E & M coding or if other Medicare or Medicaid billing guidelines are not being followed. It can also identify trends that may eventually help increase revenue through improved chart documentation and correct coding assignments.
The next step is the preparation of a written corporate compliance plan. A good compliance plan not only helps reduce and prevent the potential for unintentional error or mistakes but also serves as a mitigating factor in the settlement process following a investigation where compliance errors or patterns have been discovered.
To that end, the following list was compiled to help you know what must be included in your compliance plan.
EIGHT STEP GUIDE TO DRAFTING A COMPLIANCE PLAN
Policy Statement
This should be a Code of Conduct
Purpose
State the purpose.This should be a simple statement relating to the fact that the practice will comply to all governmental contracting laws and regulations, as well as, practice policies and procedures.
Implementation and Scope
Selection of a compliance officer and identification of employees who are exposed to potential regulatory issues.
Contracts with all third-parties should be included.
Compliance Standards and Procedures
These should address potential areas of risk and exposure and what the practice will do to avoid them. This is a method that the practice will employ that allows employees to confidentially report any potential non-compliance.
Internal Auditing and Monitoring
This is an indication of your monitoring system that will ensure compliance. An external consultant should review your billing/coding/documentation annually.
Training Programs
A program addressing how the practice will educate current and new employees relative to both your compliance program and compliance in general should be included in your plan.
Discipline for Program Violations
All employees should be made aware of the practices’ policy regarding potential violations of policies, standards, and regulations that place the practice at risk for non-compliance.
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