Do you have a compliance program in your office?
An effective compliance program, which must include measures to prevent, detect and correct billing, coding, appointments and privacy are part of the entire compliance program.:
1. Written Policies, Procedures, and Standards of Conduct;
2. Compliance Officer, Compliance Committee, and High-Level Oversight;
3. Effective Training and Education;
4. Effective Lines of Communication;
5. Well-Publicized Disciplinary Standards;
6. Effective System for Routine Monitoring and Identification of Compliance Risks; and
7. Procedures and System for Prompt Response to Compliance Issues.
In order to be effective, a compliance program must be fully implemented and should be tailored to each office or unique organization, operations, and circumstances. A compliance program will not be effective unless owner devotes adequate resources to the program. Adequate resources include those that are sufficient to do the following:
1. Promote and enforce its Standards of Conduct
2. Promote and enforce its compliance program;
3. Effectively train and educate its governing body members, employees and compliance officer
4. Effectively establish lines of communication within itself and between itself and compliance officer
5. Oversee compliance with Medicare Part C and D requirements;
6. Establish and implement an effective system for routine auditing and monitoring; and
7. Identify and promptly respond to risks and findings.
CMS will consider a sponsor’s size, structure, business model, activities, the extent of its delegation of responsibilities to other entities, the breadth of its operation, and the risks it faces in evaluating whether adequate resources have been devoted to the compliance program.
Contact Links2Success to learn more about compliance issues.