Provider practices are required to develop and implement compliance programs aimed at detecting fraud, waste, and abuse for claims which they seek reimbursement, however, few have a compliance program in place thus putting them at risk of penalties and/or prosecution.
Provider compliance programs shall, at a minimum, be applicable to billings to and payments from the government carriers but need not be confined to these payors. Compliance programs should include at minimum the following requirements:
Written policies and procedures that describe compliance expectations as embodied in a code of conduct or code of ethics, implement the operation of the compliance program, provide guidance to employees and others on dealing with potential compliance issues, identify how to communicate compliance issues to appropriate compliance personnel and describe how potential compliance problems are investigated and resolved. InterMedCorp has developed many of these policy and procedures manauals in the past. In most cases we can start from a template to accelerate the process. Our expertise assist in developing a custom result.
Perform an independent claims review to investigate and offer documented assistance and advice on proper coding, procedures and reimbursement. A designated internal employee must be identified to work with the independent company (usually an outside company like InterMedCorp). This employee may have other duties so long as compliance responsibilities are satisfactorily carried out; such employee shall report directly to the entity's chief executive or other senior administrator and shall periodically report directly to the governing body on the activities of the compliance program. InterMedCorp can provide the third party review, develop corresponding advice and assist in the implementation of such changes.
Training and education of all affected employees and persons associated with the provider, including executives and governing body members, on compliance issues, expectations and the compliance program operation; such training shall occur periodically and shall be made a part of the orientation for a new employee, appointee or associate, executive and governing body member. InterMedCorp will work to develop a custom training program including materials, implementation and tracking.
Communication lines to the responsible compliance position, as described in the second bullet above, that are accessible to all employees, persons associated with the provider, executives and governing body members, to allow compliance issues to be reported; such communication lines shall include a method for anonymous and confidential good faith reporting of potential compliance issues as they are identified. We can work to develop the proper (acceptable) communication plan to meet all requirements.