Elements Of An OIG Compliance Program

Any doctor or entity receiving reimbursement from a federally funded health care program such as Medicare, Medicaid, Tri-Care, etc. is required to have compliance program based on Seven (7) Elements as described in the Federal Sentencing Guidelines. The 7 Elements are;

  1. Assign a designated Compliance Officer.
  2. Have open lines of communication to the Compliance Officer.
  3. Have written policies and procedures specific to your practice.
  4. Conduct training and education for all employees and staff members.
  5. Perform audits (baseline) and internal monitoring to determine effectiveness
  6. Enforce standards through well publicized guidelines.
  7. Respond promptly to detected offenses and take corrective measures.

It is recommended to have baseline audits conducted by trained certified individual(s) in order to obtain a non-biased overview of patient chart documentation and compliance program requirements for your practice.

There is another element for an OIG Compliance Program which incorporates Ethics into the program. Your compliance program must include Exclusion List checks for all employees, staff members, vendors and any other individual who could be possibly paid from federal money.  These checks need to be made on newly hired employees as well as on a monthly to quarterly basis depending on the number of employees and employee turnover rate within your practice.

A requirement of the OIG Compliance Program is to have a designated OIG Compliance Manual that is continually being updated with policies and procedures. This manual is to be separate from the required HIPAA Compliance manual.  Both manuals are to be kept in the office at all times.

Medical Compliance Specialists, Ltd., has developed/created a written policy and procedure manual which can be easily customized to your specific office as OIG has stated that a off-the-shelf policy manual is not considered to meet the compliance requirements.

Need assistance with your OIG Compliance Program?  

Contact us at 708-922-3911.

About Diane M. Barton, DC, MCS-P, CIC & James Minx MCSP, CIC

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