Coding and Compliance
The Office of the Inspector General (OIG) makes it clear:
Federal health care enforcers expect all providers to implement effective compliance programs and to include in those programs specific policies, procedures and other mechanisms to prevent and detect illegal activity.
In response to this requirement, MMA has developed a comprehensive Compliance Program, which includes the following elements:
Model Billing Compliance Plan
The Model Billing Compliance Plan provides the medical practice with a customizable document designed to meet the OIG’s requirements. The Implementation Plan provides step-by-step instructions and related forms to simplify what can be a very complex process. The Utilization Profiler is a web-enabled tool developed by MMA to benchmark E&M utilization against specialty and locality specific Medicare norms.
This Compliance Program provides you with internal controls and procedures that promote adherence to statutes and regulations applicable to Federal health care programs and private insurance program requirements. It also has a well-defined self-monitoring and self-reporting policy. In our experience, having an active compliance program in place may help mitigate potential penalties related to investigation of compliance incidents. Failure to have such programs may be viewed as willful defiance of the rules.