decisionhealth Newsletters, Answer Books - 2009 Issue 3 (March)
OIG Model Compliance Plan / Compliance Tips and Tools / Maintaining a Compliance Plan
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Article Overview
This article outlines a practical checklist for organizations that already have a compliance program in place and need to maintain it over time. It reviews major areas of compliance oversight, including financial relationships, federal participation requirements, documentation practices, and reimbursement claims processes. The guidance is aimed at health care administrators, compliance officers, billing leaders, and managers responsible for internal controls and periodic program review.
Why This Topic Matters
Maintaining a compliance plan helps organizations identify weaknesses before they lead to regulatory, billing, or referral-related problems. The article is useful for teams that need a broad, recurring self-audit framework covering both operational and legal compliance areas.
Article Sections
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I. Begin by checking compliance with Anti-kickback and Stark regulations
This section reviews financial relationship oversight and referral-related compliance within health care organizations. It focuses on evaluating contracts, compensation structures, vendor interactions, and related internal review processes.
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II. Next, look at your organization's compliance with federal rules regarding delivery of health care services
This section addresses operational and regulatory compliance related to service delivery. It covers licensure, participation standards, accreditation history, documentation controls, review processes, and staff training.
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III. Finally, look at compliance with federal rules regarding claims for reimbursement for health care services
This section covers billing and reimbursement oversight. It emphasizes checking the accuracy of billing information, sampling records, and verifying the flow of information from medical records to claims forms.
What You Will Learn
- How to review a compliance program on a recurring basis
- What broad areas of health care compliance should be monitored
- How organizations can assess internal controls related to referrals, billing, and documentation
- Why periodic audits and training are important to compliance maintenance
Who Should Read This
- Compliance officers
- Health care administrators
- Billing managers
- Practice managers
- Hospital and clinic leadership
- Risk management teams
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