Prior compliance plans provide physician model
To date, the Office of the Inspector General (OIG) has issued specific compliance guidelines for hospitals, clinical laboratories, home health agencies, third-party medical billing companies, durable medical equipment companies, and hospices. Each of the guidelines was based on these seven elements:
1. development of written policies and procedures;
2. designation of a compliance officer and other appropriate compliance bodies;
3. development and implementation of effective training and education programs;
4. development and maintenance of effective lines of communication;
5. enforcement of standards through well-publicized disciplinary guidelines;
6. use of audits and other evaluation techniques to monitor compliance;
7. development of procedures to respond to detected offenses and to initiate corrective action.
When the OIG releases its physician model compliance plan, the American Medical Association wants the agency to provide details on the following topics:
• who can and can’t be a compliance officer;
• what the expected duties of a compliance officer will be;
• what constitutes adequate employee compliance training;
• how specific compliance policies and procedures must be;
• the kind, frequency, and number of specific compliance information practices that must be communicated to employees;
• how practices should discipline employees who violate compliance procedures;
• what constitutes an appropriate compliance audit or evaluation technique;
• how a practice can demonstrate acceptance of responsibility when problems arise and show it is taking corrective actions, including steps to prevent similar problems from happening again;
• whether physicians can share plan information or plan initiation and implementation costs with other independent physicians.
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