On the Heels of Medicare Fraud Sweep, Advice on Creating a Compliance Program

Recently we told you more than 300 people were charged with healthcare fraud involving some $900 million in false billings. Surely some were out to juke the system, but others were probably guilty of nothing more than poor compliance practices. Either way, the government is likely to continue cracking down on this multibillion dollar waste, making it a prudent time to shore up your own compliance program (as required under the Affordable Care Act [ACA, or “Obamacare”] anyway). Following are seven “core elements” the ACA recommends for an effective compliance program:

1. Establish and adopt written policies and procedures to promote your practice’s commitment to compliance.
2. Appoint a compliance officer—someone who will be responsible for monitoring compliance efforts and enforcing practice standards.
3. Establish reporting systems to encourage individuals to make complaints regarding compliance items without fear of retaliation.
4. Conduct formal education and training programs for all levels of employees.
5. Do ongoing auditing and monitoring of systems to assess the effectiveness of the compliance program and identify issues.
6. Develop policies to enforce standards of conduct, with disciplinary measures for employees who fail to comply with requirements.
7. Act quickly to correct vulnerabilities or suspected violations as soon as they’re discovered.