HEALTHCARE COMPLIANCE
10 RED FLAGS
Under current law, physicians are required to maintain an effective, comprehensive compliance program to detect, correct and prevent incidences of non-compliance with state and federal regulatory law. Goals of a comprehensive compliance program is to prevent the significant criminal and civil penalties that might come with a violation of the False Claims Act, Stark, the Anti-Kickback Statutes, HIPAA and state law equivalents. Failure to comply might lead to exclusion from health payments. Here is a summary of the core components of a complete compliance plan:
#1 MISSING OR INCOMPLETE WRITTTEN POLICIES, PROCEDURES AND STANDARDS OF CONDUCT
#2 PEOPLE: NO COMPLIANCE OFFICER OR COMPLIANCE COMMITTEE
#3 TRAINING: THE FACILITY LACKS EFFECTIVE TRAINING AND EDUCATION
#4. COMMUNICATION: THE FACILITY LACKS
#5. PERSONEL: FAILURE TO PUBLISH DISCIPLINARY STANDARDS & TO EFFECTIVELY DISCIPLINE VIOLATORS
#6. NO SYSTEM TO AUDIT AND MONITOR ORGANIZATION COMPLIANCE AND COMPLIANCE RISKS
#7 FAILURE TO CREATE PROCEDURES TO PROMPTLY RESPOND TO IDENTIFIED ISSUES AND SELF DISCLOSURE OBLIGATIONS
#8. LACK OF SUPPORT FROM PHYSICIANS AND LEADERSHIP OF THE ORGANIZATION
#9. FAILURE TO INSTITUTE PRIVATE HEALTH INFORMATION POLICIES
#10. FAILURE TO MONITOR NEW LAW AND UPDATE COMPLIANCE ACCORDINGLY
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