Published in HCCA Compliance Today
To date, most smaller physician practices have not taken the time or effort to develop a compliance program, long advocated by the U.S. Department of Health & Human Services (HHS) Office of Inspector General (OIG) in their voluntary compliance guidance.1 Physician practices may see a compliance program as just another burden on their limited resources that could be set aside for a future time. Well, that time is now approaching. Under Section 6401 of the Patient Protection and Affordable Care Act (PPACA),2 healthcare entities and providers, including physician practices of all sizes, must establish a compliance program that will be defined by the Centers for Medicare & Medicaid Services (CMS). These core elements will be mandated, as a condition of enrollment in Medicare, Medicaid, and the Children’s Health Insurance Program (CHIP). Entities will have to attest to or certify their compliance with these standards as a condition of participation in federally funded programs. CMS has not yet published these standards in the Federal Register. However most larger healthcare entities have already implemented compliance programs based on the seven elements of the OIG voluntary compliance program guidance that will be the basis of the new mandated program standards. In this, they have a major jump start over those entities that have held back on their compliance program development. Now, smaller physician practices will not have the option of staying on the sidelines.
- OIG Compliance Program for Individual and Small Group Physician Practices; Notice 65 Fed. Reg. 194; October 5, 2000. Available at http://1.usa.gov/1np3hDY
- Patient Protection and Affordable Care Act, 42 U.S.C. § 6401; 2010
This article was originally published in the November 2014 edition of HCCA Compliance Today. Published here with permission.
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