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ance officer would ideally report to the board of directors or to a board committee. In small and solo prac- tices, the compliance officer should report to upper-level management.


4. Conduct appropriate and effective training and education. Medicare and Medicaid compliance requirements are constantly changing, so training is crucial. Ms. Hill recommends at least annual training that could include an overview of the related fraud and abuse statutes, details about the com- pliance plan and how it works, the identification of the compliance of- ficer, and the role of each employee in the compliance plan. She also en- courages medical practices to have a hotline or phone number employees can call to report possible compliance violations.


5. Respond appropriately and promptly to detected offenses, and develop a plan to correct them. When a medi- cal practice detects a compliance violation, it must take appropriation action. The compliance officer should form a corrective action plan and should launch an investigation upon receiving a report or complaint of a compliance problem.


6. Develop open, effective lines of com- munication. An effective compliance plan allows employees to report sus- pected violations easily and without fear of retaliation. OIG suggests creat- ing anonymous alternatives, such as a drop box, for reporting suspected violations, or a statement in the prac- tice’s policies and procedures manual that not reporting suspected errone- ous or fraudulent conduct violates the compliance program.


7. Enforce disciplinary standards through well-publicized guidelines. A written policy helps medical practic- es ensure fairness and consistency in the application of discipline, Ms. Hill says. Informing physicians and staff members of disciplinary guidelines for compliance violations should be part of annual training.


The fraud and abuse landscape is full of legal landmines. Physicians may want to seek professional help.


MEMBER FDIC


“It might be wise for a practice to se-


cure qualified legal counsel or special- ized experts to review coding and billing practices, outside relationships, medical documentation, or the compliance plan itself,” Ms. Hill said.


TMA Practice Consulting offers cus-


tomized coding and documentation training, as well as reviews and chart


audits. To inquire about these services, contact TMA Practice Consulting by tele- phone at (800) 523-8776 or by email at practice.consulting@texmed.org. All ser- vices are available for a fee based on a practice’s needs.


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