Do you have the top 3 essential compliance components in your therapy program or practice? You may have a compliance plan that you wrote, or purchased a compliance program off the shelf, or maybe your compliance program consists of chart audits and quality reviews. The Office of the Inspector General (OIG) has provided Compliance Guidances that are based upon the seven key compliance elements tied to the Federal Sentencing Guidelines. Perhaps you have been meaning to develop a formal compliance plan in light of the Affordable Act’s mandate.
Getting started with the Top 3 Essential Compliance Components
In the absence of a fully implemented compliance program, or while you are developing a program there are 3 essential compliance elements that you should have in place to demonstrate commitment to compliance as well as to mitigate potential problems should they occur:
- Conduct exclusions checks to ensure you are not hiring an individual or entity that has been excluded from participation in federal health care programs. You should start with the OIG LEIE list, and then proceed to the Medicaid list for states in which you provide services. Not all states upload their lists to the OIG. The duty on the provider is to ensure that the individual and/or entity have not been excluded. Therapy providers should conduct license verifications including review of any action on the license. The premise of the OIG in seeking remedies against providers hiring excluded individuals is “known or should have known.” Exclusions checks is a provider burden.
- Have a monitoring and auditing program in place to ensure that you are routinely examining items that can prevent an infraction (monitoring) and an auditing program to ensure that you are examining compliance with document ion, billing and coding rules and other associated risks based upon healthcare statutes and guidance. For therapy providers a good audit place to start is documentation technical compliance as well as medical necessity and coding compliance.
- Train and educate staff regarding basic Medicare requirements for documentation, coding and billing. Read any OIG audit report and you will always find a sentence similar to this: “These deficiencies occurred because PROVIDER did not have a thorough understanding of Medicare reimbursement requirements related to outpatient therapy services and did not have adequate policies and procedures to ensure that it billed services that met Medicare requirements.”
While you are getting the top 3 essential compliance components integrated in your practice be sure to put implementation of a full compliance plan on your “To Do List”. Check the guidances provided by the OIG. In addition to elements of a compliance program they include associated risks specific to the provider type. The Affordable Care Act requires compliance, but final rules have not been proposed or implemented, starting now means getting ahead of the game of protecting your practice.
Do you have a compliance plan? Does your practice document that you check the OIG exclusions list and verify licenses? Do you have a monitoring and auditing program in place? Do you have policies in place and train your staff to ensure that documentation, coding and billing meet Medicare requirements?
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