Wednesday, April 22, 2009

How to Create a Compliance Program

The Department of Health and Human Services and Office of Inspector General provide a model compliance program under the compliance program for Individual and small Group Physician Practices.

It states the seven elements of a model compliance program are as follows:


  • Designation of a compliance officer and compliance committee
  • Development of compliance policies and procedures
  • Establishment of open lines of communication
  • Appropriate training and education
  • Internal monitoring and auditing of claims
  • Response and corrective action to detected deficiencies
  • Enforcement of disciplinary actions

Do you have a compliance officer in place in your medical practice ? Develop a compliance manual binder and place it in each department so that each department has access to it. It is also wise to place it online for easier updates as policies change. It is a good idea to schedule monthly meetings for the sake of new employees and updates. Not a bad idea to take advantage of webinars and conferences if cost is an issue then there are some offered from time to time at no cost from various vendors. Do not forget to have an internal monitoring or checklist for auditing claims should be included in the manual.

There should also be a section detailing what steps will be taken to respond when errors are found and also suggestions to prevent these types of errors from happening again. Perhaps a suggestion box can be placed in each department for ideas that can be implemented. Don’t forget to list disciplinary actions that will be taken for infractions of the rules and follow through. This will ensure your practice stays in compliance while creating a more productive work environment.

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