The Office of the Inspector General’s (OIG) physician compliance training recommendations can be vague. Differentiating between mandatory and voluntary requirements is difficult, and finding training materials can be challenging.
Let’s take a moment to analyze the issues surrounding corporate compliance training, and determine what your practice needs to do to ensure accuracy when billing Medicare and Medicaid.
What is CCT?
The Patient Protection and Affordable Care Act (PPACA) enacted in March 2010, requires health care providers who treat Medicare and Medicaid patients to adopt a health care compliance plan as protection against fraud.
Section 6401 of the PPACA specifically states that health care providers must establish a compliance program containing certain “core elements” as a condition of enrollment into Medicare, Medicaid, or the Children’s Health Insurance Program (CHIP). Although HHS has yet to issue regulations defining these “core elements,” it is important to start training and distributing resources to your staff now.
With enforcement initiatives increasing in frequency, particularly with respect to Medicare Fraud, health care providers currently without compliance plans should take a look at CMS’ recommended guidelines to protect themselves.
A helpful compliance plan will enable providers to avoid or at least mitigate the hefty penalties associated with violations of existing health care regulations.
However, at the moment, the only providers currently mandated to enact CCT plans are Medicate Advantage (MA) managed care and prescription drug (Part D) entities.
Establishing a CCT Program
Enacting a compliance program can help practicing physicians avoid fraud and ensure they are submitting accurate claims. Yet, implementing proper training can be tricky.
We suggest following these seven steps when planning a strong compliance program:
1) Conduct regular monitoring and auditing of Medicare billing practices.
2) Train all new staff members on compliance and practice standards.
3) Designate a compliance officer to be in charge of Medicare/Medicaid issues.
4) Conduct training for all existing staff members.
5) Encourage open lines of communication between staff members.
6) Set guidelines backed by disciplinary standards.
7) Finally, if CMS detects an offense, respond quickly and correctly.
Training Resources
Finding the right information to teach is often the hardest part of creating a CCT plan. In response, CMS has published several resources that will help providers meet CCT criteria.
The following educational materials are meant to teach physicians about the federal laws designed to protect Medicare and Medicaid beneficiaries from fraud, waste and abuse.
Compliance Program Guidance for Individual and Small Group Physician Practices.
A Medicare Roadmap for New Physicians and an accompanying PowerPoint will help you educate your staff on the CCT.
Remember, the most important step in maintaining an effective compliance program is providing continuously updated, expert compliance education to your practice’s physicians and staff members. Take the issue head-on to avoid OIG’s watchful eye. The last thing you want to deal with is a Medicare audit.
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