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A sound compliance plan keeps lawsuits at bay, builds employee trust.

Ambulatory Safety Monitor, June 11, 2003

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If convicted of health care fraud, you will likely suffer a lesser fine if your organization has a compliance plan. Plus, the government expects you to have one.

Those are two vital reasons for adopting a compliance plan. Consider these additional compliance plan tips:

1. Auditing and monitoring-Perform regular internal audits to detect whether employees bill as they should, among other issues. The compliance officer-or other appropriate person-uses on-site visits, interviews, paperwork, and performance improvement studies to ensure that people follow the plan.

TIP: A baseline audit gives you a frame of reference to make comparisons, says attorney Beth Connor Guest of Waller Landsen Dortch & Davis PLLC in Nashville, TN. Space these audits no less than two years apart.

TIP: Look at past mistakes as learning tools. "Don't place the blame on the people, but tell them that they need to fix their ongoing mistake," says Guest.

Who has time to audit and monitor? Look at your resources. A large corporation can ask someone from corporate to take over. Smaller organizations can hire an outside consultant. But understand that auditing and monitoring are the most important elements of your compliance plan, Powers says.

2. Written policies and procedures-The government likes to see your compliance plans, procedures, and policies on paper, so write it all down.

Develop written policies and procedures to look at specific concerns uncovered during the audit, as well as useful ways to prevent risky situations from happening again. These include unlawful coding and billing, unreasonable and unnecessary patient visits, the failure to document all patient care plans, and improper inducements, kickbacks, and self-referrals.

"You need to write down rules on how you would address these problems," Guest says.

TIP: Write down your policy in clear, simple English. Treat it like a living document and update it as needed.

This week's tip was excerpted from Briefings on Ambulatory Accreditation, a monthly publication that reports on the activities of the ambulatory care accreditors, the JCAHO and the AAAHC. It illustrates exactly what you and your staff need to do to pass a survey and gain accreditation so that your organization is known for quality and can affiliate with other delivery systems. For more information, or to subscribe, click here.

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