decisionhealth Newsletters, Answer Books - 2009 Issue 3 (March)
OIG Model Compliance Plan / Step 6 - Respond to Detected Violations / Step 6 - Respond to Detected Violations
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Article Overview
This article covers the response phase of a compliance program after possible violations are detected. It focuses on internal assessment, corrective action planning, reporting considerations, monitoring for warning signs, and broader compliance program review. The content is relevant to compliance officers, providers, legal counsel, and healthcare organizations working to maintain effective compliance procedures.
Why This Topic Matters
Responding appropriately to suspected non-compliance helps organizations limit risk, strengthen compliance processes, and address issues before they recur or escalate. The article is useful for readers who need a high-level understanding of post-detection compliance responsibilities in a healthcare setting.
Article Sections
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Responding to Detected Violations
Introduces the need to assess suspected non-compliance and determine an appropriate corrective response. Discusses general considerations for reviewing allegations and addressing potential violations.
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Monitoring and Warning Indicators
Describes examples of internal indicators that may signal compliance problems and warrant follow-up. Focuses on oversight, pattern recognition, and monitoring within the organization.
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Overpayment and Internal Assessment
Addresses post-detection review activities related to overpayments and internal evaluation of reported concerns. Emphasizes the need to examine confirmed issues and consider program-wide follow-up.
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Preventing Recurrence and Reassessing the Program
Discusses steps to avoid compounding a discovered violation and the importance of reviewing compliance procedures after an incident. Covers ongoing program reassessment and updates to internal controls.
What You Will Learn
- How organizations generally respond after detecting possible compliance violations
- What types of internal warning indicators may prompt follow-up
- Why overpayment and misconduct concerns may require broader internal review
- How post-detection findings can lead to compliance program reassessment
Who Should Read This
- Compliance officers
- Healthcare providers
- Billing and coding professionals
- Healthcare administrators
- Legal counsel
- Corporate compliance teams
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