E/M Coding Alert - 2009 Issue 4
COMPLIANCE: Tackle Your Compliance Questions With 2 FAQs
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Article Overview
This article answers two reader questions about healthcare compliance and enforcement. It discusses general considerations for preparing annual compliance reports to the OIG under a corporate integrity agreement and explains, at a high level, how civil monetary penalties may relate to exclusion actions and Medicare participation. The piece is aimed at practices, compliance staff, and advisors who handle reporting and enforcement-related correspondence.
Why This Topic Matters
Healthcare organizations can face significant risk when responding to oversight requirements or enforcement actions. Understanding the general scope of reporting obligations and the possible relationship between monetary penalties and exclusion helps practices recognize when experienced compliance or legal support may be appropriate.
Article Sections
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Button Up Your Annual Reports
Discusses annual reporting expectations associated with a corporate integrity agreement and the role of internal or outside assistance in preparing compliance-related submissions to the OIG.
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CMP Does Not Require Exclusion
Explains the general relationship between civil monetary penalties, exclusion considerations, settlements, and continued participation in Medicare.
What You Will Learn
- What types of compliance reporting issues may arise under an OIG corporate integrity agreement
- Why organizations may seek outside help with compliance-related submissions
- How civil monetary penalties can be discussed separately from exclusion actions
- What broad enforcement and settlement topics are associated with OIG oversight
Who Should Read This
- Physician practices
- Compliance officers
- Office managers
- Healthcare attorneys
- Healthcare consultants
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