This episode is the beginning of a series about corporate integrity agreements. One of the important elements that is part of a corporate integrity agreement is implementing a compliance program. Why is it so important to have a compliance program? What should it consist of? How can a compliance program save your practice? Find out in this episode of Talking with the Toothcop!
Outline of This Episode
- [2:40] Corporate integrity agreements
- [4:41] Compliance program guidelines
- [6:48] Why you want to implement a compliance program
What is a corporate integrity agreement (CIA)?
A corporate integrity agreement addresses a specific issue while attempting to accommodate or recognize the elements of compliance programs. A CIA typically lasts for five years with a certain amount of requirements attached. What are those requirements?
- The organization must hire a compliance officer and appoint a compliance committee
- They have to develop written standards and policies
- They must implement a comprehensive employee training program
- Retain an independent review organization to conduct annual reviews
- Establish a confidential disclosure program
- Restrict employment of eligible persons
- Report overpayments, events, ongoing investigations, and legal proceedings
- Provide implementation reports to the OIG on the status of compliance activities
A large part of demonstrating compliance is creating a compliance program. What should that consist of?
Compliance program guidelines
The OIG provides compliance guidance documents for the healthcare sector, including dental practices. Regardless of what sector of healthcare you’re in, these compliance guidelines center around 7 elements of compliance:
- Conduct internal monitoring and auditing processes
- Implement written policies and procedures
- Designate a compliance officer and compliance committee
- Conduct effective compliance training and education
- Respond promptly to violations and take timely corrective action
- Develop effective lines of communication
- Enforce standards through well-publicized disciplinary guidelines
A corporate integrity agreement is agreeing to create a compliance program—with the added bonus of a babysitter, the independent review organization.
The best way to learn is from others' mistakes, right? It’s less painful and less costly. Compliance programs are NOT cheap. The government wants you to feel the pinch. They expect you to invest time, money, and effort into compliance.
Why you want to implement a compliance program
Long before the OIG came out with guidance, the US Judiciary came up with federal sentencing guidelines that existed for different types of crimes. Chapter 8 deals with healthcare fraud. The OIG compliance guidelines come directly from these US Federal Sentencing Guidelines.
If an organization gets busted for something—but has a reasonably effective compliance program in place—it can reduce fines and penalties up to 90%. When an organization is busted, the government's first ask after an audit is the highest amount. It can be millions of dollars. If you can reduce that by 90%, it can take $1 million down to $100,000. That’s a big deal.
That is where your return on investment comes in. An effective compliance program will pay off. But it’s also my goal that our clients never realize this investment. These are systems that you need to implement. When it comes to compliance, there’s no such thing as “Set it and forget it.”
Resources & People Mentioned
- LIVE Compliance Training
- Compliance Guidance for Individual and Small Group Physician Practices
- Compliance Program Guidance for Third-Party Medical Billing Companies
- TWT Episode: The 7 Elements of Dental Compliance Programs