OIG to publish ambulance guidance
Compliance Monitor, August 23, 2000
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The Department of Health and Human Services' Office of Inspector General verified late last week that it will create ambulance industry compliance guidance. In the June issue (Vol. 4, No. 6), Corporate Compliance Officer--Compliance Monitor's sister publication--reported that Assistant Inspector General Lewis Morris signaled the OIG's intention to develop industry guidance for ambulance providers. In last Thursday's Federal Register (Vol. 65, No. 160, p. 50204), the OIG solicited input and recommendations from the ambulance industry and interested parties. This industry guidance will not be in the mold of previous model compliance programs, states the OIG. The agency refers to its latest endeavor as "Compliance Risk Guidance" (CRG) and states that it will "concentrate on specific identified risk areas and related compliance program best practices." "It will just be more specific to the identified risk areas," OIG spokesperson Judy Holtz said last Friday. The CRG will restate some positions made by the OIG in past advisory opinions--the agency has published seven dealing with ambulance-related issues in addition to a proposed rule concerning ambulance restocking. But the CRG also will identify new risk areas and compliance best practices, according to Holtz. The request states that comments must be received by 5 p.m. on October 16, 2000. Holtz said that the Office of Counsel has put the CRG on a "fast track." "We have been working with the OIG for some time in trying to give input into the compliance guidance," said Darrel Grinstead, counsel for the American Ambulance Association, which has published a sample ambulance compliance program for its members. "Essentially we're looking for confirmation from the OIG that the things we have in our manual are what ambulance companies need to have in their own compliance programs." Grinstead suspects that most of the risk areas in the CRG will focus on billing issues, such as billing for the appropriate level of service and not billing for unnecessary services. Access the Federal Register online at www.access.gpo.gov/su_docs/aces/aces140.html
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