Corporate Compliance

Make Stark compliance a priority this year

Health Care Auditing Strategies, February 1, 2009

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Auditors should conduct assessments to check financial arrangements and ensure compliance. “Auditors need to be reviewing for Stark Act compliance, generally. Look at contracts; make sure a lawyer has reviewed them,” Wade says.

Unlike other audits, which usually entail a sample of claims to review for mistakes, Stark Law audits examine a facility’s behavior and relationships, making these assessments less clear-cut, says Julie Chicoine, JD, RN, CPC, compliance director at the Ohio State University Medical Center in Columbus.

“It’s not a coding or billing rule, so you’re not going to find a Stark violation on a claim,” Chicoine says. “And because it’s a relationship issue, the OIG enforcement has been through either voluntary disclosure and settlement with the government or whistleblowers.”

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