decisionhealth Newsletters, Answer Books - 2009 Issue 3 (March)
DME Model Compliance Plan / Overview
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Article Overview
This article explains the purpose and scope of the Office of Inspector General’s model compliance plan for durable medical equipment suppliers. It is aimed at providers, suppliers, compliance staff, and billing teams who want a high-level understanding of the program framework, required internal controls, training, communication, response, and enforcement elements commonly discussed in OIG compliance guidance.
Why This Topic Matters
DME suppliers operate in a heavily regulated environment, and this overview helps readers understand the compliance program concepts and risk-management areas emphasized by OIG. It is relevant for organizations building or reviewing internal compliance processes related to supplier operations, billing practices, and fraud-and-abuse prevention.
Article Sections
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OIG model compliance plans for health care providers
Introduces the purpose of OIG model compliance plans and places the DME supplier plan in the broader context of other provider guidance. It also frames the plan as a preventive compliance resource.
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DME supplier scope and definition
Describes who is considered a DME supplier and the general scope of items and services covered in the discussion. It references the regulatory and statutory framework used to define suppliers and covered supplies.
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Common elements of OIG model compliance plans
Summarizes the shared structure used across OIG’s model compliance plans. This section introduces the seven-step compliance framework and the major topic areas included in it.
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Step 1: Audit and monitor
Covers the first part of the compliance framework focused on oversight and ongoing monitoring. The section notes related subtopics such as standards, procedures, and record retention.
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Step 3: Designate compliance officer and committee
Addresses organizational responsibility for compliance oversight. The section includes the role of compliance leadership and how compliance may be incorporated into performance expectations.
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Step 4: Train and educate
Discusses training and education as part of the compliance program framework. It references program format, continuing education, and billing-related training as general areas covered.
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Step 5: Develop effective lines of communication
Explains the communication component of a compliance program. The section refers to reporting channels and access to compliance leadership.
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Step 6: Respond to detected violations
Addresses response processes when potential issues are identified. The section references self-disclosure as part of the broader compliance response framework.
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Step 7: Enforce disciplinary standards
Covers enforcement and disciplinary expectations within the compliance program. The section lists common risk areas and related oversight topics discussed in the article.
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Compliance tips and tools
Provides a closing reference point for practical compliance support materials. This section serves as a general wrap-up to the overview.
What You Will Learn
- How OIG frames a model compliance plan for DME suppliers
- What broad components are included in a supplier compliance program
- Which general compliance functions are emphasized in OIG guidance
- What major fraud-and-abuse risk areas are highlighted at a high level
- How the article situates DME supplier compliance within broader provider compliance planning
Who Should Read This
- Durable medical equipment suppliers
- Compliance officers
- Billing and coding staff
- Health care administrators
- Provider operations teams
Codes Discussed
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