You may have heard about the “Seven Elements for an Effective Compliance Plan.” In fact, if you enter that term in a popular web browser “about 575,000” results appear within seconds. Fortunately, compliance and enforcement agencies endorse the elements and provide great examples on what to do – without having to delve much into those results. The purpose of this guide is to provide basic guidance and after that, if you wish to explore the remaining 574,999 resources, you’ll have rudimentary knowledge to sort out what is or is not good advice.

Implementing a compliance program can seem overwhelming, something that only a large medical center or hospital can implement because they have more people to do the work. Even small to medium sized practices can create a compliant culture with their providers and staff. Ultimately, patient care and safety, including getting paid for work performed are common goals no matter how many patients you see or however many staff are employed by your healthcare clinic.

While there are many consultants available to help you out, the Office of Inspector General (OIG) itself offers a guide [1] to help medical systems or practices implement their own programs. This article will refer to the OIG’s guide, as well as provide links to other free materials provided by the Centers for Medicare and Medicaid Service (CMS) and the Medicare Administrative Contractors. Most people like you and me want to get paid for services in a compliant manner and CMS and the MACs want to pay us in a compliant manner especially since the OIG is providing oversight over everyone’s activities.

This guide will cover the following topics and a few others:

• The Seven Elements for an effective compliance plan
• Why do external entities audit and how can practices mitigate any findings?
• The Office of Inspector General (OIG) is and its role is in relation to compliance oversight
• The OIG Annual Work Plan

Citations:

[1] OIG Healthcare Compliance Program Tips: https://oig.hhs.gov/documents/provider-compliance-training/945/Compliance101tips508.pdf (accessed 8/18/24)