Provider Compliance Programs: Every Private Medical Practice Should Have One
This post goes out to all those private medical practices that are under the impression that they are too small or too insignificant to draft and implement a comprehensive compliance program. You know who you are.
What are you doing to protect your patients medical records from inappropriate examination or theft? How do you ensure that your practice is consistently billing and coding “clean claims”? How will your prove that your employees are trained in handling protected health information?
Auditors, attorneys and inspectors will not be amused when they ask to see your compliance manual and you, in turn, point to the “employees only” sign on your wall. Every single private medical practice is subject to the rules and regulations of powerhouses such as HIPAA, and is thereby encouraged to have a formal corporate compliance program. And I am not talking about a 1,000 page binder that would take an entire week to read. To the contrary, a comprehensive compliance program consists of seven fundamental elements:
- Implement written policies, procedures and standards of conduct
- Designate a compliance officer to be responsible for execution of the compliance program
- Conduct effective and consistent employee training and education
- Develop lines of communication for employees, patients and private citizens
- Enforce compliance standards through well-publicized disciplinary guidelines
- Conduct regular internal monitoring and auditing
- Respond promptly to detected offenses and develop a strategy for corrective action
The trick is to take these seven elements, transform them into a simple set of written guidelines that are tailored to meet the needs of the individual practice, and then incorporate them into the practice's daily routine.
