Corporate Compliance

Auditing against the OIG Compliance Program Guidance for Hospitals

Healthcare Auditing Weekly, February 17, 2006

Today, we'll continue last week's discussion of verifying compliance officer duties against the OIG Compliance Program Guidance for Hospitals. Including the duties we discussed last week, further verify that the compliance officer

  • ensures that independent contractors and agents who furnish medical services to the hospital are aware of the compliance program's requirements for coding, billing, and marketing

  • coordinates personnel issues with the hospital's human resources office to ensure that the facility regularly checks the National Practitioner Data Bank and the OIG's list of excluded individuals and entities

  • assists the hospital's financial management in coordinating internal compliance review and monitoring, including annual or periodic reviews of departments

  • independently investigates and acts on matters related to compliance, including designing and coordinating internal investigations and resulting corrective action with all hospital departments, providers, and independent contractors

  • develops policies and programs that encourage managers and employees to report suspected fraud and other improprieties without fear of retaliation

  • has the authority to review all documents and other information related to compliance activities, including patient records, billing records, records concerning marketing efforts of the facility, and records concerning the hospital's arrangements with other parties, including employees, professionals on staff, contracts, etc.

  • has the authority to review contracts and obligations that may contain referral and payment issues that could violate the anti-kickback statute, Stark, or other legal or regulatory requirements

    Next week, will continue our discussion with a breakdown of steps for verifying compliance committee responsibilities.

      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.

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