‘Crafting Effective Compliance Plans for Physician Groups’ Series: OIG Compliance Program Guidance
‘Crafting Effective Compliance Plans for Physician Groups’ Series: OIG Compliance Program Guidance
This article marks the second installment in our ongoing series, “Crafting Effective Compliance Plans for Physician Groups.” Stay tuned for future articles that will delve deeper into specific compliance areas and best practices for physicians.
Running a successful physician practice requires juggling many priorities, but ensuring compliance with regulations shouldn’t be one of them. The good news is, the Office of Inspector General (OIG) offers a roadmap to success with its through its document titled “OIG Compliance Program for Individual and Small Group Physician Practices.”
This OIG compliance program guidance, specifically designed for individual and small group practices, equips you with the tools to navigate complexities and achieve compliance excellence. Let’s go over some key takeaways:
Baseline Audits: Setting the Standard
The cornerstone of the OIG’s recommendations is the implementation of baseline audits, particularly focusing on claims and services submitted and paid within the initial three months following the roll-out of education and training programs. Think of them as a launchpad, establishing a benchmark for compliance effectiveness within the physician practice. By scrutinizing this crucial period, practices can identify areas of improvement and ensure alignment with regulatory standards.
Annual Audits: Sustaining Compliance Momentum
Maintaining compliance isnβt a one-time thing. Following the baseline audit, the OIG underscores the importance of conducting periodic audits at least once each year. These annual reviews confirm your compliance programβs effectiveness and identify any potential issues before they snowball. Consistent monitoring and evaluation are key to sustaining compliance momentum and mitigating risks of non-compliance.
Internal vs. External Auditors: Prioritizing Thoroughness & Objectivity
While the OIG document does not explicitly advocate for either internal or external auditors, it encourages practices to consult their internal compliance plan and/or compliance department for further guidance. The best choice depends on the practice’s resources, expertise, and specific needs. Internal auditors offer familiarity with the practice’s operations, while external auditors bring fresh perspectives and specialized skills. Ultimately, the choice should prioritize thoroughness and objectivity.
Sample Size Matters: Choosing the Right Amount
The OIG highlights the importance of a representative sample size during audits. While there’s no fixed formula, the OIG recommends reviewing five or more medical records per Federal payor (like Medicare, Medicaid) or five to 10 records per physician. This approach ensures a comprehensive assessment across various payors and providers. While a larger sample size enhances confidence in the results, practices must balance thoroughness with practicality, considering potential burdens.
Putting the OIG Compliance Program Guidance into Action
Navigating compliance audits in physician practices requires a strategic approach guided by the principles outlined in the OIG’s document. From baseline audits to annual assessments, and the choice between internal and external auditors, each step contributes to upholding compliance excellence and safeguarding the integrity of patient care and financial operations. By embracing these recommendations and adapting them to their unique contexts, physician practices can navigate regulatory complexities with confidence and integrity.
Remember, the OIG guidance provides a framework, but customizing it to your practice’s unique needs is crucial. For the complete OIG compliance program and in-depth details, refer to the document “OIG Compliance Program for Individual and Small Group Physician Practices.” By embracing this guidance and tailoring it to your specific situation, you can navigate regulatory complexities with confidence and ensure the continued success of your practice.
