Spring 2011 issue of Horizons

Professional Services

Implementing An Effective Compliance Program For Healthcare Providers By Steve Moro, CPA

As a part of the Patient Protection and Affordable Care Act (a.k.a. Healthcare Reform Law), all providers (including physicians) are required to adopt a compliance plan as a condition of participation in the Medicare program. The statute requires the Secretary of the Department of Health and Human Services (HHS) to adopt core elements of compliance for each type of provider in each industry segment. While the HHS has not currently issued the “core elements” of compliance nor has it established an implementation date, it appears that the compliance programs will be based on the various

compliance documents published by the HHS Office of Inspector General (OIG) over the last several years. A well designed compliance program can: • Speed and optimize proper payment of claims • Minimize billing mistakes • Reduce the chances of an audit by HHS or OIG • Avoid conflicts with anti-kickback regulations • Demonstrate a “good faith” effort of compliance to HHS Implementing a compliance program should not impact patient care but should enhance the

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