You may have heard that you should establish a compliance program in your practice, but with everything you have to do, you just haven’t had time to get to it. Good news: Susan Gillin, Senior Counsel for the OIG, gave a presentation recently on implementing a CMS compliance program. You can watch the video by clicking on the image above.
The information Ms. Gillin presents can help new practices that haven’t yet implemented a compliance program get up to speed with compliance issues. By following her practical tips, you can set up and operate a compliance program that can help to protect your practice from false claims, fraud and abuse.
Ms. Gillin covered six tips for implementing a compliance program:
- Foster a Culture of Compliance
- Create Policies and Procedures
- Train your Staff
- Promote Communication
- Take Appropriate Corrective Action
- Conduct Regular Internal Audits
Foster a Culture of Compliance
A culture of compliance is an atmosphere in the workplace where compliance is a common and ongoing concern. Employees recognize this through their employer’s investment in compliance programs, repeated communication on important topics and even celebrations for employees who bring compliance issues up as a part of their daily work.
Create Policies and Procedures
Every practice needs a set of written policies and procedures, with specific policies for each job function in the organization. Appoint a compliance officer – someone will be responsible for keeping compliance materials up to date and distributed to all employees. There are numerous resources available on the OIG website to help you get started.
Train Your Staff
Even the most complete set of policies and procedures is useless if employees don’t understand them. Compliance training should include regular instruction sessions and testing, but they can be fun, too. Ms. Gillin suggests creating games, such as Jeopardy!™, to keep employees interested and involved. There are regular conferences to attend, publications to read and ongoing issues to follow. Make training an ongoing effort, and repeat information regularly.
Promote Communication
Once your practice is up to speed with compliance, keep it front and center in company meetings, in newsletters, emails and on intranet sites. Pick specific topics to focus on for given periods of time. Encourage feedback through a dedicated hotline or an anonymous survey. Some employees will be in positions where their feedback is vital and could mean the difference between compliance and investigation. Take advantage of that information.
Take Appropriate Corrective Action
With a team that is well-trained in compliance, it’s likely that you’ll have issues reported from time to time. Ms. Gillin suggests that you create a system to record and track each issue as it comes in. Appropriate corrective action may only mean additional training in an area that had been missed previously. It may mean discipline for an employee who has a history of errors that expose the company to investigation. Another suggestion is to create an investigative board made up of members who thoroughly understand compliance issues and do not have conflicts of interest in their occupations. The Office of Inspector General has a self-disclosure protocol that you should understand and use when necessary.
Conduct Regular Internal Audits
Compliance is a form of self-enforcement, and in that spirit, the best way to determine your organizations’ understanding of compliance is to conduct an internal audit. Some areas to test include:
- Coding – Are the codes you are billing under appropriate to the care provided?
- Contracts – Are there actual or perceived conflicts of interest between parties?
- Referrals – Make sure your organization is complying with the anti-kickback statute and the physician self-referral law.
- Quality of care – Failing to meet professionally recognized standards of healthcare with respect to wound care, hygiene, appropriate administration of medication, etc., can result in penalties by OIG.
Once you have an effective compliance program in place, it’s a good idea to review it periodically. Is the hotline monitored? Are employees informed, and are enforcement plans appropriate to the issues uncovered? Are training materials updated to incorporate changes to your policies and procedures? The six tips covered above can help you to answer these questions affirmatively, and keep your organization in compliance.
Do you have a compliance program in your practice? How well does it work?
