Corporate Compliance

Ferreting out fraud and abuse in healthcare has been identified as one of the federal government’s highest priorities. The significance of corporate compliance programs has been underscored by the multimillion dollar awards that healthcare facilities have paid to settle cases brought by the government. Additionally, if a physician practice or other healthcare facility does not have a corporate compliance program and a government audit reveals wrongdoing (including honest mistakes), the government will more than likely impose financial penalties and mandate the creation of a compliance program. The government has unequivocally stated that only an effective corporate compliance program will be considered as a mitigating factor if it is going to seek sanctions against a healthcare facility or physician practice.

Compliance activity for the physician practice requires addressing a wide range of issues, including discrimination against the disabled, loss of privacy and security of health information, and adherence to mandatory reporting laws to protect the public. This Self-Assessment Questionnaire (SAQ) will focus on government investigations/audits related to Medicare and Medicaid fraud and abuse. In order to facilitate the establishment of an effective compliance plan, ECRI suggests that physician office personnel responsible for compliance efforts complete this SAQ annually and that relevant sections be repeated more frequently, if necessary. Although this SAQ suggests basic components of a corporate compliance plan, it is not intended to be all-inclusive but rather is intended as a guide to some of those questions that physician practices may wish to address. ...