Complying with the Office of the Inspector General’s guidelines regarding the hiring of excluded individuals, as well as with other guidelines from Health and Human Services and state agencies, is an essential part of ensuring the legal and financial standing of your healthcare organization. But how can you build a strong program to address OIG healthcare compliance? Here are five tips suggested by the OIG, as well as some explanation on how to put them into effect:
- Make Compliance Plans a Priority
Not only can compliance programs save your organization money by avoiding monetary penalties, an OIG healthcare compliance program is now mandated under the Affordable Care Act. Empower either an individual or a committee (depending on the size of your organization) to oversee compliance. To help with the actual mechanics of OIG exclusion checks, you can choose an exclusion screening software system or hire an outside firm to carry out investigations on employees and contractors.
- Know Your Risk Areas
Regular internal audits and exclusion screening can help you recognize any problems early on. You can also look at the OIG’s yearly Work Plan to get an idea of where federal regulators are cracking down, and getting an external audit at least once every three years is smart, since it’s better for a private firm to find problems and report them to you than it is for problems to show up in an official investigation.
- Manage Your Financial Relationships
It’s important you have written policies for your interactions with and billing procedures involving physicians and referral sources.
- Don’t Follow Competitors
Just because your competitors are doing something doesn’t mean that you should assume it’s in line with government policy or risk-free. You should check with your own legal counsel before implementing any policies or practices.
- When in Doubt, Ask for Help
The responsibilities of OIG healthcare compliance can be confusing and overwhelming at all levels. It’s important to open up communication to let anyone in your organization know that they can reach out to their superiors for guidance on compliance issues. Compliance officers should also know that help is available from outside firms and information sources. And finally, you should remember that self-reporting problems to the OIG, while it can come with penalties, ultimately reduces risk and is a far better route than staying silent and crossing your fingers everything will work out.
Do you have any other tips to share for building or managing an effective compliance program? Discuss these ideas and any others in the comments.