The seven components of the recommended OIG Compliance Plan are:
1. Conducting internal monitoring and auditing through the performance of periodic audits
2. Implementing compliance and practice standards through the development of written standards and procedures
3. Designating a compliance officer or agent to monitor compliance efforts and enforce practice standards.
4. Conducting appropriate training and education on practice standards and procedures.
5. Responding appropriately to detected violations through the investigation of allegations and the disclosure of incidents to appropriate Government entities.
6. Developing open lines of communication to keep practice employees updated regarding compliance activities.
7. Enforcing disciplinary standards through well-publicized guidelines.
The final guidance also identifies four specific compliance risk areas for practicing physicians:
1. Proper coding and billing.
2. Ensuring that services are reasonable and necessary.
3. Proper documentation.
4. Avoiding improper inducements, kickbacks, and self-referrals.
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For a copy of the draft Compliance Program please click below: