Does your practice have a compliance program in place? If not, now is the time to build one. Compliance programs can help create an environment that prevents, detects and corrects misconduct on the job. Compliance programs can also help reduce the likelihood of fraud, waste and abuse.
Neighborhood strongly recommends that all its providers, business associates and subcontractors develop compliance programs and regularly evaluate their effectiveness. Effective compliance programs consist of (but are not limited to) the following elements:
- Distribute a written code of conduct and policies to promote a commitment to compliance (e.g., by including compliance as part of job performance appraisals). The code of conduct and policies should address potential fraud areas such as claims management and financial relationships with other providers.
- Appoint a Chief Compliance Officer and others to run and monitor the compliance program.
- Offer compliance training for staff.
- Implement processes (such as a confidential hotline) to receive potential fraud complaints.
- Create procedures to protect the anonymity of those who report actual or perceived wrongdoing, and protect whistleblowers from retaliation.
- Deal well with complaints. Take appropriate disciplinary action(s) if staff violate compliance requirements.
- Audit and monitor compliance with business requirements.
- Investigate and solve systemic problems.
For tips and information on how to create a compliance program specific to your practice, see the compliance guidance documents prepared by the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG):
- For individual and small group physician practices (65 Fed. Reg. 59434; October 5, 2000): https://oig.hhs.gov/authorities/docs/physician.pdf
- For hospitals (63 Fed. Reg. 8987; February 23, 1998 and 70 Fed. Reg. 4858; January 31, 2005): https://oig.hhs.gov/authorities/docs/cpghosp.pdf and https://oig.hhs.gov/fraud/docs/complianceguidance/012705HospSupplementalGuidance.pdf
- For ambulance suppliers (68 Fed. Reg. 14245; March 24, 2003): https://oig.hhs.gov/fraud/docs/complianceguidance/032403ambulancecpgfr.pdf
- For clinical laboratories (63 Fed. Reg. 45076; August 24, 1998): https://oig.hhs.gov/authorities/docs/cpglab.pdf
- For the durable medical equipment, prosthetics, orthotics and supply industry (64 Fed. Reg. 36368; July 6, 1999): https://oig.hhs.gov/authorities/docs/frdme.pdf
- For home health agencies (63 Fed. Reg. 42410; August 7, 1998): https://oig.hhs.gov/authorities/docs/cpghome.pdf
- For hospices (64 Fed. Reg. 54031; October 5, 1999): https://oig.hhs.gov/authorities/docs/hospicx.pdf
- For nursing facilities (65 Fed. Reg. 14289; March 16, 2000 and (73 Fed. Reg. 56832; September 30, 2008): https://oig.hhs.gov/authorities/docs/cpgnf.pdf and https://oig.hhs.gov/compliance/compliance-guidance/docs/complianceguidance/nhg_fr.pdf
- For third-party medical billing companies (63 Fed. Reg. 70138; December 18, 1998): https://oig.hhs.gov/fraud/docs/complianceguidance/thirdparty.pdf