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