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Follow the Work Plan to Improve Compliance

The Doctor's Office, February 5, 2009

Every physician office needs a compliance plan—a written document that outlines proper policies and procedures for coding, billing, and managing other regulations that apply to physician practices. Ideally, your compliance plan will keep you out of hot water with the Office of Inspector General (OIG) and health plan or government auditors.

But should you be accused of noncompliance, simply having a written plan protects a practice from penalties and other damages that can be levied against it in the event of incidents without intent. Not developing and implementing a compliance plan essentially removes those protections.

Although most facilities have such a plan, some are slow to adjust their policies based on changes within the practice. Others simply fail to follow procedures defined within their plan. It's crucial to keep compliance a priority, however, to avoid government penalties and withheld reimbursement.

"The OIG Work Plan is the government crystal ball," says Curtis J. Udell, CPAR, CPC, senior advisor at Health Care Advisors, Inc., in Annandale, VA.

The Work Plan outlines seven general guidelines for compliance plan development and implementation:

1. Conduct internal monitoring and auditing.

2. Establish policies and procedures that include an examination of risk areas specific to your practice, such as those relating to coding and billing; reasonable and necessary services; documentation; and improper inducements, kickbacks, and self-referrals.

3. Designate a compliance officer or contact to monitor compliance efforts and enforce practice standards.

4. Conduct compliance training, particularly in regard to coding and billing.

5. Respond to and investigate detected violations, disclose any such incidents to the appropriate government agencies, and develop corrective action initiatives.

6. Keep the lines of communication open via discussions at staff meetings or community bulletin boards. Janet Burch, administrator at Pikes Peak Nephrology Associates, PC, a nine-provider practice in Colorado Springs, CO, says to delegate some of the development and implementation work to staff members, making the process a team effort. "It allows everyone to take more ownership in the practice," Burch says.

7. Publicize guidelines and enforce disciplinary standards.

These seven elements are just a starting point for practices' compliance efforts, says Udell. "It must be an active part of practice operations," he says, noting that regular reviews, revisions, and updates are crucial for any plan.


This article was adapted from one that originally appeared in the February 2009 issue of The Doctor's Office, a HealthLeaders Media publication.

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