OIG to issue compliance guidelines for physicians.
Interventional physicians, like many other small physician practices, are bracing for a soon-to-be released document from the Office of the Inspector General (OIG) for the Department of Health and Human Services that will provide guidance to physician practices interested in developing compliance programs for their practices. The purpose of these compliance programs is to demonstrate to government authorities that a provider has made an institutional commitment to adhere to all relevant laws as a matter of everyday practice, and may establish a strong basis for minimizing any penalties if a violation actually occurs. Even though these guidances issued by OIG are non-binding, they are particularly useful as they reflect the OIG's position on a wide range of compliance issues directly impacting physician practices. Physician compliance documents should include the elements that OIG believes are crucial for an effective plan including: written compliance policies and procedures, compliance officer/compliance committee, effective training and education, effective lines of communication, disciplinary protocols to enforce the plan, monitoring and auditing of the plan/program, and responsiveness to detected offenses and the development of corrective action plans.
Peters
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Arent Fox Klinter Plotkin & Kahn, PLLC, Washington, DC 20036, USA.
Sarraille
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