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What Medicaid Dentists and DSOs Need to Know About Corporate Integrity Agreements

When a dentist or DSO (or any other healthcare entity) get busted for Fraud, Waste or Abuse (FWA) issues the government may decline criminal prosecution in favor of a civil settlement known as a Corporate Integrity Agreement (CIA). There is much to unpack about CIAs. Here is what I know: Corporate Integrity Agreements have become a favorite tool of the federal government. You can gain valuable insights on how to protect your practice by reading CIAs (and other government enforcement actions). Every CIA includes requirements that the organization incorporate the OIG’s seven core elements (8 if you're a New Yorker)...

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The Lowdown on Written HIPAA Policies and Procedures

To be HIPAA compliant Covered Entities (Dental Offices and DSOs) and Business Associates are required to have written policies and procedures, know them, follow them, and enforce them! Sadly this is something ALMOST every dental office fails to comply with. You may have a HIPAA manual, but has it been tailored to your practice setting. Have you and your employees read them, understood them, follow them, abide by them?    When it comes to HIPAA there are some terms you should know. For this post, the term of the day is ‘Workforce’.   Your workforce is your employees, volunteers, trainees, and other persons...

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Fools Rush In by Tink

A movie called Fools Rush In came out in 1997 (worth noting this was over 20 years ago). Three years later in October 2000 the federal Office of the Inspector General (OIG) established written compliance program guidelines for Individual and Small Group Physician Practices. The OIG’s compliance guidelines outline seven elements as voluntary measures individual and small group physician practice (and dental practices) should implement in effort to demonstrate their commitment to prevent criminal fraud and a high level of corporate integrity.    The seven elements include:  1.     Implementing written policies, procedures and standards of conduct. 2.     Designating a compliance officer and...

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Sometimes You've Got To Be Your Own Snitch

Sometimes when you mess up – and that mess up involves Medicare, Medicaid, or funds from another government healthcare program – not only do you have to fix the mess, but you may also have to go back and make amends to limit your liability and hedge against civil and/or criminal prosecution later. Hospitals do it. Physician groups do it. Ambulance providers do it. Home health does it. What? Get busted for coding, documentation, and billing problems. The federal government developed the Self-Disclosure Protocol (“SDP”) for healthcare providers to be able to bring themselves forward to the government in a...

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GUEST POST: Website Disclosures Pursuant to the Board’s Business Promotion Rules - By Laura Diamond, Attorney

In today’s environment, a practice website is a nearly essential element to a well-rounded marketing strategy. A strong website is an effective and cost-efficient way to promote a dental practice. It also can provide information to current and prospective patients. Practice websites are considered business promotion by Texas State Board of Dental Examiners and must comply with the Board’s rules regarding advertising.       Overall, the Board’s business promotion rules require dentists to communicate truthfully to the public. To that end, Rule 108.59 delineates the four essential disclosures required by dental practice websites. These components represent the minimum information...

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