Compliance Program Guidance
Medicare's DMEPOS Quality Standards require that suppliers "shall implement business practices to prevent and control fraud, waste, and abuse." The Office of Inspector General publishes a General Compliance Program Guidance document offering a comprehensive framework that organizations of all sizes and types can use to create a compliance plan.
What You Need to Know
The OIG's GCPG lists 7 elements essential to an effective compliance program:
- Establishing written policies and procedures that clearly define expected conduct, outline applicable laws and regulations, and describe consequences for violations.
- Designating compliance officer and compliance committee - individuals and groups with the authority, resources, and independence to oversee the program day-to-day.
- Training and education tailored to employees' roles and responsibilities.
- Providing employees accessible, confidential means to report concerns or potential violations, including anonymous hotlines, without fear of retaliation.
- Internal monitoring and auditing - e.g., proactively reviewing billing practices, coding accuracy, and business relationships.
- Creating clear disciplinary standards and enforcing them consistently.
- Responding promptly to detected offenses.
What This Means for You
A well-functioning compliance program can reduce legal risk, improve operational efficiency, and foster a culture of integrity. The OIG's GCPG provides a comprehensive set of standards that you should review and compare to your existing compliance program. Importantly, the GCPG includes suggested adaptations to the 7 standards based on your organization's size as well as links to additional resources. You can access the GCPG here.