Corporate Compliance

Auditing against the OIG's Compliance Program Guidance for Hospitals

Healthcare Auditing Weekly, January 10, 2006

Today, we'll continue instructions for auditing against the OIG's Compliance Program Guidance for Hospitals. This week, we'll discuss strategies for auditing anti-kickback and self-referral concerns.

Hospitals must have policies and procedures in place to ensure compliance with federal and state anti-kickback statutes, as well as the Stark physician self-referral law. Determine whether policies and procedures exist to ensure the following:

  • All of the hospital's contracts and arrangements with referral sources comply with applicable statutes and regulations

  • The hospital does not submit claims for patients who were referred to the hospital pursuant to contracts and financial arrangements designed to induce referrals in violation of the anti-kickback statute, Stark, or similar federal and state regulations

  • The hospital does not enter into financial arrangements with hospital-based physicians which are designed to provide inappropriate remuneration to the hospital in return for the physician's ability to provide services to government healthcare program beneficiaries at the hospital

    Next week, we'll discuss strategies for auditing policies and procedures related to bad debts.

      The above tip is an excerpt from the book "Hospital Auditing and Monitoring: Sample Programs for Key Risk Areas." Copyright 2004 by HCPro, Inc. This book is a step-by-step, practical manual that offers sample audit programs for the most troublesome areas that a hospital must audit. The binder and CD-ROM are filled with actual audit programs used by auditors and compliance officers in the field. Click here for more information or to order your copy today.

        • Strategies for Health Care Compliance

      • Strategies for Health Care Compliance

        News and real-life examples to increase the effectiveness of your compliance program. Strategies for Health Care Compliance...

      • Compliance Monitor

        This HTML e-mail newsletter delivers news on Medicare and Medicaid fraud and abuse, as well as recent documents and targets...

      • Medicare Weekly Update

        Each issue of Medicare Weekly Update includes the latest CMS proposed and final rules, CMS manual revisions, and...

      • Medicare Update for Physician Services

        Medicare Update for Physician Services is a free, monthly e-zine that delivers news and information to help physician...

      Most Popular

      Related Articles