Basic training for hospital employees
According to Washington, DC-based law firm Reed Smith Shaw & McClay, whose attorneys have seen a copy of the draft Model Compliance Plan for Hospitals circulated by the Office of the Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS), the following key elements should be included in basic training for all hospital employees to avoid any brush with Medicare fraud and abuse:
Medicare reimbursement principles
Prohibitions on receiving direct, overt payment for Medicare or Medicaid referrals
Billing Medicare and Medicaid for services that are not rendered
Misrepresenting the nature of the services rendered to receive reimbursement
Submitting a bill for physician services when rendered by a non-physician
Signing for physicians without physician authorization
Alterations to medical records
Billing in violation of bundling regulations
Billing for investigational research and developmental devices, medications, and procedures without proper authorization
Attending physician and resident requirements for teaching hospitals
Violating patient transfer policies
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