Compliance

The OIG believes that every compliance program should begin with a commitment to address the seven elements of an "effective" Compliance Program. Based on the seven elements set form in the Federal Sentencing Guidelines, defined as:

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1. Establishing compliance standards through the development of a code of conduct and written policies and procedures.

2. Assigning compliance monitoring efforts to a designated compliance officer or contact who reports to the governing authority.

3. Conducting comprehensive training and education on practice ethics and policies and procedures.

4. Conducting internal monitoring and auditing, focusing on high-risk billing and coding issues through performance of periodic audits and risk assessments.

5. Developing accessible lines of communication, such as discussions at staff meetings regarding fraudulent or erroneous conduct issues and community bulletin boards, to keep practice employees updated regarding compliance activities.

6. Enforcing disciplinary standards and ensuring employees are aware that compliance is treated seriously and that violations will be dealt with consistently and uniformly.

7. Responding appropriately to detected violations through the investigation of allegations and the disclosure of incidents to appropriate Government entities when appropriate.

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While many practices have compliance programs - at least in spirit - these are now mandatory for all Medicare and Medicaid providers, regardless of specialty. Acevedo Consulting has years of experience developing and implementing compliance program tailored to physician practices, both large and small.

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It's clear that the Medicare program is paying more attention to services billed by physicians through increased use of ADRs. CMS' goal is to reduce/prevent improper payments. And, as all government budgets tighten, it should not be surprising that the Medicare program will continue to look for potential overpayments through the audit process. Acevedo Consulting was deeply involved with the Recovery Audit Contractor's audits during the 3-year Florida demonstration program. Allow our experience and expertise to aid you in preparing for the inevitable audit.