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Are you giving yourself credit for compliance?
Government sanctions can be mitigated by a compliance program that pre-dates the offense--but only if that compliance program is effective. It is up to the provider to show that its compliance program is working. |
Prove it
How will you prove the success of your compliance program to investigators? Your compliance program should leave a paper trail. The following are some of the documents that should be readily available:
- Your Compliance Program, Code of Conduct, and other compliance policies and procedures
- Compliance meeting minutes and reports to the Board/CEO
- Efforts to comply with laws and Federal health care program requirements (including written correspondence from, and a log of conversations with carriers, FIs, CMS, etc.)
- Employee training records and background checks
- Records of compliance monitoring and auditing activities, such as chart audits and claims reviews
- Contracts and other documents relating to financial relationships, and reports of legal review of those relationships
- Records of compliance discipline policies and disciplinary actions taken
- Compliance hotline logs, investigation records and corrective action reports
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MPA can help
Management Performance Associates can help you implement compliance policies and procedures. To learn more about how your compliance program can help you avoid penalties, please visit our website: http://www.healthcareperformance.com, or give us a call at 314-434-4227 ext. 24. |
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Margaret Scavotto
General Counsel & Compliance Manager
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