Compliance Program Requirement

Russell B. Still, CVA, CHBC
Executive Vice President

Under the Accountable Care Act, physicians and other healthcare providers treating Medicare, Medicare Advantage, Medicaid and CHIP patients are required to have an active compliance program to meet requirements and avoid regulatory violations contained in HIPAA, OSHA and the Federal False Claims Act.

Of particular concern is the presence of an active and monitored billing compliance program, as many practices still believe this to be voluntary. The purpose of the billing compliance program is to assist providers in preventing the submission of erroneous claims or engaging in unlawful conduct involving federal healthcare reimbursement programs.

The Office of the Inspector General (OIG) has been working to update the guidance documents, but has instructed practices to base their programs on the October 5, 2000 Compliance Program Guidance for Individual and Small Group Physician Practices. The original OIG guidance was voluntary in 2000; it is now mandatory. (https://oig.hhs.gov/authorities/docs/physician.pdf)

The OIG Seven (7) Components of an Effective Compliance Program are:

1. Written standards of conduct and policies and procedures (required within ninety [90] days for new employees and annually thereafter);
2. A designated compliance officer or contact person;
3. Comprehensive training and education;
4. Accessible lines of internal communication;
5. Enforcement of standards through well-published disciplinary guidelines;
6. Internal monitoring (daily, weekly or monthly) and auditing; and
7. Prompt response to detected offenses and prompt undertaking of corrective action.

Medical Management Associates, Inc. (MMA) has a comprehensive compliance plan that includes step-by-step instructions for adopting and implementing these seven (7) components. We are available to assist you in this process by training your staff, providing auditing services, developing responses to offenses and designing corrective action measures.

If your practice does not have a billing compliance plan, MMA can help you with this. In addition, MMA offers HIPAA and OSHA compliance plans and training programs. Contact us to assist you in developing and implementing these plans, as well as training your staff on an annual basis.

If you have questions or would like assistance with any of these programs, please contact Russ at rbs@medicalmanagement.com or 770-951-8427.