Compliance Program Benefits

Numerous benefits can be gained by implementing an effective compliance program. These benefits may include:

• Development of effective internal procedures to ensure compliance with regulations, payment policies and coding rules
• Improved medical record documentation
• Improved education for practice employees
• A reduction in the denial of claims
• More streamlined practice operations through better communication and more comprehensive policies
• The avoidance of potential liability arising from noncompliance and
• Reduced exposure to penalties.

The OIG, for example, will consider the existence of an effective compliance program that pre-dated any governmental investigation when addressing the appropriateness of administrative sanctions. However, the burden is on the physician practice to demonstrate the operational effectiveness of the compliance program. In addition, an effective compliance program that was in place at the time of the criminal offense may mitigate criminal sanctions.

Practices should view compliance programs as analogous to practicing preventive medicine. An effective compliance program also sends an important message to a practice’s employees that while the practice recognizes that mistakes will occur, employees have an affirmative, ethical duty to come forward and report fraudulent or erroneous conduct, so that it may be corrected.

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