tci Medicare Compliance & Reimbursement - 2013 Issue 15
Compliance: Make Sure Your Compliance Plan Meets ACA Requirements
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Article Overview
This article discusses ACA compliance plan requirements for Medicare, Medicaid, and CHIP participation and explains why providers should pay attention to CMS and HHS guidance as it develops. It also reviews the general compliance-program framework commonly used as a reference point, along with broader billing, coding, privacy, and organizational considerations for physician practices and other providers.
Why This Topic Matters
Providers and suppliers need to understand how ACA compliance requirements may affect enrollment and reenrollment in federal health care programs. The article is relevant to organizations building or updating compliance programs and to those tracking CMS, OIG, and HHS guidance that may shape implementation expectations.
Article Sections
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Compliance plan requirement under the ACA
Introduces the ACA compliance plan requirement and its relationship to participation in federal health care programs. Provides the regulatory context for providers and suppliers of different sizes.
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CMS final rule status and implementation uncertainty
Explains the status of CMS guidance and the uncertainty created by the absence of a final rule. Discusses the roles of CMS, HHS, and the OIG in shaping future expectations.
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Using existing compliance guidance as a model
Describes the use of older compliance-program guidance as a practical reference point until newer rules are issued. Notes the broader compliance topics that physician groups and other organizations should consider.
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Core compliance program components
Lists the general components commonly used to structure a compliance program. Focuses on organizational processes, training, monitoring, communication, and corrective action.
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Practice-specific review and updating
Emphasizes the need to tailor a compliance plan to the specialty or facility and to review it when operations change. Highlights the importance of legal review and ongoing maintenance.
What You Will Learn
- How the ACA relates to compliance program expectations for participation in Medicare, Medicaid, and CHIP
- Why CMS and HHS guidance matters for implementation
- What general compliance framework elements are commonly referenced
- Why compliance plans should be tailored to the organization and updated over time
Who Should Read This
- Physicians
- Medical practice administrators
- Compliance officers
- Billing and coding professionals
- Healthcare attorneys
- Provider enrollment staff
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