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“The compliance plan should permeate into how the practice conducts business and should provide a basis for creating an environment where people can easily raise concerns while having their identities protected.”

Policies & Procedures: A Guide for Medical Practices, published by TMA, contains a section on compliance to help medical practices implement and en- force their own programs. A hard copy of the guide with customizable CD is $295 for members and $395 for nonmembers. The customizable CD alone is $255 for members and $355 for nonmembers. To order the guide, call the TMA Knowledge Center at (800) 880-7955, or email

Stick to the plan

OIG developed compliance program guidelines for individual and small group physician practices that can help prevent the submission of erroneous claims.

OIG issued seven core elements that compliance programs must possess to continue participation in federal health care programs:

group can follow than a complicated one that doesn’t apply to the practice,” Ms. Hill said.

Detect and correct With increased emphasis on recouping money for federal health programs, it is pivotal physicians use their compliance programs to quickly detect and correct billing and coding mistakes. “The compliance plan should perme- ate into how the practice conducts busi- ness and should provide a basis for cre- ating an environment where people can easily raise concerns while having their identities protected,” Dr. Sheff said. ARC takes measures to ensure that

its roughly 300 physicians implement and adhere to the compliance plan. Dr. Sheff says the ARC governance commit- tee reviews the plan annually, and the executive board receives an annual com- pliance report. ARC provides compliance plan train- ing and education each year to physi-


cians and staff members in the form of PowerPoint presentations.

“The educational sessions focus on the fundamentals of compliance and allow us to highlight any specific areas such as new regulations or updated information,” Dr. Sheff said. The Texas Medical Association has

resources to help physicians craft a com- pliance program. TMA’s Fraud and Abuse publication has a section focused on helping physicians identify and imple- ment an appropriate compliance pro- gram to adhere to the laws, regulations, and guidelines that pertain to solo and small group practices.

TMA also offers a step-by-step guide

to creating a compliance program avail- able in print and electronic format. Ms. Hill wrote both publications. To pur- chase Fraud and Abuse, visit http://bit .ly/VFk2AP. To purchase the guide to creating a compliance program, visit the TMA Education Center, http://texmed

1. Conduct internal monitoring and au- diting. Ms. Hill says, ideally, at least two people — a billing staff member and at least one medically trained professional — should conduct cod- ing and documentation audits. These reviews are an opportunity to com- pare the medical record with the claim form to determine correct cod- ing and services, complete and timely documentation, and the reason and necessity for services.

2. Implement compliance and practice standards. Written standards and procedures help reduce the risk of im- proper billing practices by identifying risk areas and establishing tighter in- ternal controls to counter those risks, Ms. Hill says. At least one practice member should monitor standards and procedures to ensure they are current and complete and should inform employees of changes and updates. When establishing practice standards and procedures, Ms. Hill recommends physicians consider any billing weaknesses or practice areas that may attract scrutiny. (See “Iden- tify Fraud and Abuse Red Flags,” page 24.)

3. Designate a compliance officer. In a group practice setting, the compli-

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