Elements of an Effective Compliance Program for Your Practice

BY TALIA GOLDSMITH
MMS PPRC ADVISOR

Compliance governs personnel matters, billing and coding issues, privacy and security, and many other transactions. Without a compliance plan, a practice may be at risk if audited and could potentially face significant penalties. Every medical practice should have a compliance plan in place, regardless of practice size.

The U.S. Department of Health and Human Services’ Office of Inspector General has issued guidance for practices. Its recommendations include seven core elements:

  1. Internal monitoring and auditing.Periodic audits and on­going monitoring help you identify potential gaps and opportunities for improvement.
  2. Promotion of compliance and practice standards.Written policies and procedures are important to include in your compliance plan, but determining how to best implement the ­policies and procedures in a manner that will promote ­compliance within your practice is key.
  3. Designate a compliance officer or contact.Assign a key individual in the practice who can take ownership of implementing and maintaining the compliance plan.
  4. Conduct appropriate training and education.Educate staff on policies and procedures, maintain ongoing yearly trainings, and monitor compliance with policies and procedures.
  5. Respond appropriately to offenses and develop corrective action.It is important to respond to inquiries of potential violations or allegations in a timely manner. If you detect a potential offense, seek appropriate legal assistance to help guide you through the appropriate reporting process.
  6. Keep lines of communication open.It is important to maintain good communication with your staff around policies, procedures, and steps to avoid erroneous or fraudulent conduct. It is also important to communicate specific policies and procedures (such as HIPAA privacy and security) with your patients.
  7. Have well-publicized standards and expectations for how staff handle patient information.Having standards and expectations outlined is important so that staff is not just trained on key compliance areas but understand the expectations of the practice in relation to the compliance plan and overall policies and procedures.

Contact the PPRC today to find out how we can assist you in building a compliance plan. Call (781) 434 7702, or reach us online at www.massmed.org/pprc or pprc@mms.org.

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