OIG
Effective Compliance Program - The Seven Basic Elements
by A. Maureen Hanna
OIG
Effective Compliance Program -
The Seven Basic Elements
by A. Maureen Hanna
Element # 3 - Conducting effective training and education
As part of a compliance program, suppliers should require all affected personnel to attend training on an annual basis. New employees should be targeted for training early in their employment. The general training sessions should emphasize the supplierís commitment to compliance, summary of fraud and abuse laws and regulations, Federal, State, and private payor health care program requirements, claim submission procedures and marketing practices that reflect current legal and program standards.
All relevant levels of personnel should be made part of various educational and training programs. Employees should be required to have a minimum number of educational hours per year. Failure to comply with training requirements should result in disciplinary actions, including possible termination of employment. A variety of teaching methods, such as interactive training and training in several different languages (if applicable) should be implemented so that all affected employees are knowledgeable. Training materials should be designed to take into account the skills, knowledge and experience of trainees. Training instructors may come from outside or inside the organization.
General Training Session
As part of the initial training, the standards of conduct should be distributed to all employees. At the end of the session, every employee, as well as physicians, independent contractors, and other significant agents should be required to sign and date a statement that reflects their knowledge of an commitment to the standards of conduct. This attestation should be retained in the employeeís personnel file. For physicians, independent contractors, and other significant agents, the attestation should become part of the contract.
Claim Development and Billing Session
Training of appropriate corporate
officers, managers and other claim development and billing staff
should include such topics as:
Specific Government and private payor reimbursement principles;
Requirements for medical necessity documentation;
Appropriate claim form completion;
Improper alterations to documentation;
Compliance with Federal, State, and private payor supplier standards;
Duty to report misconduct;
When is it (or not) appropriate to complete a form on behalf of
a physician; and
Prohibition of routine waiver of coinsurance and/or deductible.
Sales and Marketing Session
Primary training to sales and
marketing personnel, corporate officers and managers should include
such topics as:
Prohibition of paying or receiving renumeration to induce referrals;
Routine waiver of deductible and/or coinsurance;
Disguising referral fees as salaries;
Offering free items or services to induce referrals;
High pressure marketing of non-covered or unnecessary services;
Improper patient solicitation; and
Duty to report misconduct.
In order to maintain a sense of seriousness about compliance in a providers operations, the supplier must continue to disseminate the compliance message. This can be accomplished via email, company newsletter and face-to-face meetings. If utilizing any of these modes for education, the provider should maintain the newsletters, email and/or lecture notes in a central location to document the guidance offered.
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