Why you need a compliance program
December 1, 1997 2 minutes read
Why you need a compliance program
Clean your room voluntarily or Mom will come in and do it for you. And you don’t want that.
A corporate compliance program is your opportunity to prevent, find, and eliminate fraud yourself. That’s always a better option than waiting for the government to come in and do it, because then you will be forced to abide by a strict set of requirements that will make life very difficult. And that’s on top of the actual penalties you pay. And that’s assuming, of course, that you aren’t kicked out of the Medicare program entirely.
John C. West, JD, MHA, and John Steiner, JD, both assistant legal counsel with the American Hospital Association in Chicago, offer this description of what is likely to happen if the federal government investigates you and forces you to accept an "integrity plan:"
• Government monitoring will last for three to five years.
• Government inspectors will have the right to inspect all documents, conduct on-site reviews, and use independent auditors.
• You will have to provide annual reports to the investigators.
• Education and training programs will be mandatory.
• A material breach of the integrity program can lead to exclusion from Medicare.
• The settlement agreement and the corporate integrity plan will be public records, subject to disclosure through the Freedom of Information Act.
• Outside, independent reviews will be required.
• Penalties and costs are not deductible under IRC Section 162, nor may they be included on cost reports.
• Federal agencies will monitor your program continuously and share the information with state agencies.
• The federal agencies must give prior approval to any sale, acquisition, merger, or reorganization involving the institution.
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