Corporate Compliance

Auditing against the OIG’s Compliance Program Guidance for Hospitals

Healthcare Auditing Weekly, March 14, 2006

Auditing against the OIG's Compliance Program Guidance for Hospitals

This week, we will continue our discussion of auditing against the OIG's Compliance Program Guidance for Hospitals with staff training topics your facility should cover. In addition to the risk areas identified last week, compliance training to appropriate corporate officers, managers, and other hospital staff should include the following topics:

  • Government and private-payer reimbursement principles

  • General prohibitions on paying or receiving remuneration to induce referrals

  • Proper confirmation of diagnoses

  • Submitting a claim for physician services when rendered by a nonphysician

  • Signing a form for a physician without the physician's authorization

  • Alterations to medical records

  • Prescribing medications and procedures without proper authorization

  • Proper documentation of services rendered

  • Duty to report misconduct

    Note that employees are required to have a minimum number of education hours per year, as appropriate, as part of their employment responsibilities. Further, verify that

  • attendance and participation in training programs is made a condition of employment, and failure to comply with training requirements results in disciplinary action

  • adherence to the provisions of the compliance program, including the training requirements, factors into annual employee evaluations

  • the hospital retains adequate records of training sessions, including attendance logs and material distributed at training sessions

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