You try to follow all the rules—you stay up-to-date on industry regulations; everyone in your office has had HIPAA-specific training; your staff works hard to maintain patient privacy and security. You may have even invested in a new electronic healthcare records (EHR) system.
Even with all of these precautions, though, there is still a chance your practice could be audited. One of the best ways to prepare for such an eventuality and to protect yourself and your practice is to have a compliance plan in place.
Chiropractic services were included in three separate sections of the Office of the Inspector General’s (OIG) Work Plan for Fiscal Year 2014. The Work Plan described what the OIG does:
“We conduct audits, evaluations, and investigations; provide guidance to industry; and, when appropriate, impose civil monetary penalties, assessments, and administrative sanctions. We collaborate with HHS and its operating and staff divisions, the Department of Justice (DOJ) and other executive branch agencies, Congress, and States to bring about systemic changes, successful prosecutions, negotiated settlements, and recovery of funds.” 1
Chiropractic services were included multiple times in the Work Plan, which could imply that chiropractic practices may be more heavily audited, evaluated, and investigated than in the past. Having an appropriate compliance plan in place can give you and your staff peace of mind.
In 2000, the OIG published the “OIG Compliance Program for Individual and Small Group Physician Practices,” which is a useful guide for DCs who would like to implement a compliance plan in their practice.2 Despite the changes that have occurred since 2000, the suggestions in the program are still valid. The publication also offers step-by-step guidance on how to implement a compliance plan a little bit at a time in recognition of the time and financial constraints that small practices face.
The components of the plan include:2
- Setting up internal auditing and monitoring procedures
- Implementing standards
- Conducting the appropriate training
- Responding to audits and investigations
- Developing communication
- Enforcing disciplinary standards
Each part of a well-designed compliance program offers a layer of protection for your practice. For example, internal monitoring and regular auditing offers the opportunity to review procedures and catch errors, and appropriate training can keep the entire staff aware of in-office standards, state laws, and federal regulations.
There are hundreds of pages of regulations related to healthcare and insurance—it would be extremely difficult to learn the basics once and remember them forever. However, by following the standards of a voluntary compliance plan, everyone on your staff can become knowledgeable regarding the current laws and can be prepared in the case of an audit by the OIG.
1 Office of Inspector General. “Work Plan for Fiscal Year 2014.” U.S. Department of Health and Human Services. http://oig.hhs.gov/reports-and-publications/archives/workplan/2014/Work-Plan-2014.pdf. Accessed January 2015.
2 National Archives and Records Administration. “OIG Compliance Program for Individual and Small Group Physician Practices.” Federal Register. 2000:65(194);59434–59452.