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The guidelines (such as auditing, monitoring, internal controls, sampling, due diligence, and standards of organizational and employee behavior, as found on page 508 of the textbook) that physician practices should follow when creating a compliance plan. State your opinion as to which OIG guideline would be the single most significant aspect of a compliance plan for a small practice. Provide a rationale for your response.
1. Establish an effective compliance program: An effective compliance program should be tailored to the size and complexity of the practice, provide for a culture of ethical practices, set clear standards and procedures, assign responsibility and authority for monitoring, provide appropriate training and education, include periodic internal reviews or audits, develop open lines of communication with employees/vendors/payers, use appropriate incentives to encourage adherence, respond appropriately to detected offenses/irregularities including corrective action when necessary.
2. Implement written policies and procedures specifically addressing fraud and abuse risks: Elements may include a code of conduct; conflict-of-interest policy; commission/bonus plan; system for disclosing false claims and other wrongdoing; billing accuracy measures (such as pre-payment review); regular financial audits; protocols regarding vendors; contracts between physicians/providers & payers’ documentation guidelines related to medical necessity
4. Provide education regularly on applicable laws and regulations: To maintain an effective compliance program underway it is important that all staff members understand what behavior is expected from them so they can fulfill their duties ethically while adhering to both state law as well as federal regulations such as those issued by CMS or OIG. Education sessions should be held regularly so that new information can be provided when needed or changes made in existing rules explained thoroughly.
5. Monitor patient care processes using performance improvement techniques such as data analysis: Performance improvement techniques allow for trending over time which can help detect potential problems before they become systemic issues within your practice’s patient care delivery process by identifying areas where quality could potentially suffer due to inappropriate processes being followed or inadequate resources being allocated towards certain activities . By tracking this trend you can identify potential problems more quickly than if left unchecked completely which would enable you take corrective action quicker resulting in better outcomes overall for your patients while also reducing any negative financial impact caused by delays in rectifying these issues
In my opinion, establishing an effective compliance program would be the single most significant aspect of a compliances plan for a small practice because it sets out clear expectations about how operations will run day-to-day while also providing guidance around how best handle any breaches in protocol identified through internal reviews or audit activities conducted periodically throughout the year. A solid framework outlining these key aspects helps ensure everyone responsible understands what’s expected from them thus avoiding any confusion down line leading up future incidents occurring due possible misunderstandings arising out lack transparency between management team & operating personnel present organisation