I recently had the opportunity to attend a provider compliance training conference hosted by the Health Care Fraud Prevention and Enforcement Action Team (HEAT), a joint effort by the Centers for Medicare and Medicaid Services, the Department of Justice and the Office of the Inspector General for Health and Human Services.

In the notes that were provided, they list 10 practical tips for creating a culture of compliance:

1. "Make compliance plans a priority now." Mandatory office compliance programs are coming. It is expected that the final rules will be in place by the end of the year. You should be putting your compliance program in place now so that it will be operational by the time it is required.


2. "Designate (and empower!) an individual or team responsible for compliance." CMS and the OIG believe that you should have a designated staff member to conduct your office compliance program. If you cannot afford a trained staff person, they recommend that you outsource your compliance activities to a consultant. For the average chiropractic office, the best option is usually to have a designated staff member working with a consultant trained and certified in compliance.


3. "Know risk areas." The primary risk areas in any office are documentation, coding, billing, marketing and financial arrangements. Each of these areas can put you at risk of fines, penalties and possibly jail. An effective office compliance program will have procedures to identify and mitigate risks.

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