June 09, 2015
Many practices that we work with have compliance plans that gathering dust on a shelf somewhere, ignored and unused. Creating, maintaining, and updating your compliance plan is crucial given today's increased level of scrutiny on physician practices. You can make the process of creating a plan manageable by using a "skeleton" plan to assist in creating your custom plan. These skeleton or template plans are available from many different resources, or you can find free help on the OIG's website. Maintaining your plan requires an ongoing awareness of regulatory changes and payer-specific billing/coding changes that could affect your practice's revenue outlook and compliance.
When you notice changes, you must update your compliance plan to reflect these changes and update your staff as well, including educating them when necessary. These updates should occur once per year at a minimum, but it's more likely you'll need to perform them as-needed when changes come down from payers or the government. Having a compliance plan that is out of date and/or unused could be all the justification the government needs to claim that your providers are engaged in more than accidental abuse.