OIG
Effective Compliance Program - Element # 1
(Part Two)by A. Maureen Hanna
OIG
Effective Compliance Program - Element # 1
(Part Two)
by A. Maureen Hanna
Element # 1 - Implementing written policies, procedures and standards of conduct. (Continued)
As a part of its commitment to compliance suppliers should establish a comprehensive set of written polices and procedures that takes into consideration the particular statutes, rules, regulations and program instructions applicable to each function of the supplier. In contrast to the standards of conduct that we spoke of last issue, the written policies and procedures should articulate specific procedures personnel should follow.
It is recommended by the OIG that the policies and procedures be coordinated with the appropriate training and educational programs with an emphasis on areas of special concern that have been identified by the OIG. The areas of concern include:
1. Billing for items or services not
provided
2. Billing for medically unnecessary
service
3. Duplicate billing
4. Unbundling of items or supplies
5. Continuing to bill for rental
items after they are no longer medically necessary
6. Failing to maintain medical necessity
documentation
7. Falsifying information on the
claim form, and/or accompanying documentation
8. Employing persons excluded from
participation in Federal health care programs
In addition to the eight listed above, the OIG has a list of an additional 39 areas that they feel should be assessed by the suppliers and incorporated into the written policies and procedures, and training elements developed as part of their compliance program.
Tips:
1. Become familiar with the 47 areas
of concern listed by the OIG. Should you wish to obtain the complete
listing you can send an e-mail to: mhanna@primenet.com and I will be happy to forward the complete
listing to you.
2. Address all 47 areas in your company
written policies and procedures.
3. At each company meeting address
one or two of the areas of concern. Provide written examples of
these areas to each person in attendance. Have attendees sign
a form that they attended the meeting.
4. Those unable to attend the meeting
should be provided follow-up training. Again, document this training.
5. Include in appropriate job descriptions
that the individual will be responsible to understand the problem
areas.
6. Emphasize that adherence to the
written policies and procedures as well as provided training is
mandatory and failure to do so can result in disciplinary action
up to and including termination of employment.
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