decisionhealth Newsletters, Answer Books - 2009 Issue 3 (March)
OIG Model Compliance Plan / Common Fraud and Abuse Concerns / Anti-Kickback and Stark Self-Referral Concerns
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Article Overview
This article explains OIG compliance-plan guidance for providers and suppliers concerned with fraud and abuse risk. It focuses on broad policy expectations related to contracts, referral arrangements, gifts or incentives, advisory opinions, and the role of federal self-referral and anti-kickback laws. It is useful for compliance staff, practice administrators, physicians, and billing professionals who need to understand the scope of OIG guidance and the kinds of safeguards discussed in the article.
Why This Topic Matters
The article helps readers understand which compliance topics are emphasized by OIG when managing referral-related and financial-arrangement risk. It is relevant for organizations reviewing policies, maintaining compliance programs, and aligning internal procedures with federal guidance.
Article Sections
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Compliance policies and review of arrangements
Discusses the need for written policies and procedures, legal review of arrangements, and use of advisory opinion resources when evaluating potential compliance concerns.
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Claims, referrals, and inducement concerns
Covers broad compliance concerns involving referral-related claims, financial arrangements, and potential incentives offered to patients or referral sources.
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Safe harbor guidance and provider responsibility
Addresses OIG safe harbor guidance, the general responsibility of providers of different sizes, and the need for ongoing compliance monitoring.
What You Will Learn
- How OIG frames compliance planning around referral-related and financial-arrangement risk
- Why contract and arrangement review is emphasized in fraud and abuse compliance
- What general categories of safeguards are discussed for providers and suppliers
- How advisory opinions and safe harbor guidance fit into compliance programs
Who Should Read This
- Compliance officers
- Medical practice administrators
- Physicians
- Billing and coding professionals
- Healthcare attorneys
- Supplier compliance staff
Codes Discussed
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