With the passage of the Patient Protection and Affordable Care Act (PPACA) in 2010, there is an urgency for medical practices to develop and implement HIPAA and general regulatory compliance program policies and procedures. PPACA requires all healthcare providers enrolled as Medicare providers to have a full compliance program in place.
An effective overall compliance program, including HIPAA compliance, can help the practice spot errors in its processes, and prevent small problems before they become large ones. The area of most risk is in the billing practices to government healthcare programs and adhering to HIPAA Privacy and Security Rules.
One of the keys to a good compliance program is to make it truly effective. It must be more than a document initially adopted by the officers of the practice and reviewed once per year. The Office of Inspector General (OIG) of the federal Department of Health and Human Services (HHS) recommends specifics about the components of a compliance program.
- Conducting internal monitoring and auditing
- Developing and implementing compliance program policies and procedures
- Designating a compliance officer or contact person
- Conducting appropriate training and education of staff
- Responding appropriately to detected offenses and developing corrective action
- Developing open lines of communication, and
- Enforcing disciplinary standards through well-publicized guidelines.
An effectively designed compliance plan should be implemented, reviewed and enforced continually with the goals of preventing, detecting, and correcting inappropriate and potentially unethical conduct.
Reducing your exposure to liability is another key reason for implementing a compliance program. Making reasonable efforts to avoid and detect misbehavior is evidence in itself that a practice does not have intent to commit healthcare fraud, and thus, may reduce penalties if wrongdoing is found.
The design and implementation of any compliance plan will vary from one practice to another. A compliance plan from a high volume practice will differ from a low volume practice. A family practice plan will differ from that of a specialty practice. To be most effective, the plan needs be designed for the services and structure of your practice. Compliance is no longer an option, it is a requirement. DWA can provide the resources and expertise to get your practice into compliance.
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