Annual Compliance Training

LOUISVILLE As you may be aware, Section 6401 of the Affordable Care Act put into place a requirement that “providers of medical or other items or services or suppliers within a particular industry sector or category” establish compliance programs in order to enroll in Medicare and Medicaid.

In this article, we are going to focus on one of the seven elements of an effective compliance program: Education and Training.

Under guidance issued by the Department of Health and Human Services (HHS) Office of Inspector General (OIG), education and training should include general compliance training for all employees, managers, supervisors, and physicians. This training should be conducted annually for all employees, and for new employees, within 30 days of hire.

What should the training include?

Typical training elements included in the annual training are:

• Code of conduct

• The elements of the compliance program as implemented within your practice and how you are adhering to the seven elements of the compliance program as defined by OIG

• Types of relationships which may raise fraud and abuse concerns

• Review of the following regulations:

› Federal False Claims Act
› Anti-kickback Statute
› Physician Self-Referral Law
› Criminal Health Care Fraud Statute
› Exclusion Statute
› Civil Monetary Penalties Law

• A review of documentation requirements to support accurate coding and billing, including provision of examples of improper claims

• HIPAA privacy training

For those of you who are in employment arrangements with large hospital systems, you and your staff have likely received this training annually as a part of the system’s required education and training. However, for those of you who are self-employed or part of an independent physician practice, when was the last time you received or arranged for your staff to receive this training? Many of you are probably trying to remember if you have ever received or provided this type of training within your practice. You are not alone. However, you have an opportunity to address this element and implement training going forward.

Education and training is but one element in an effective compliance program. All elements of a compliance program are necessary to truly be effective in mitigating the risks to your practice from regulatory noncompliance.

Since graduating from the University of Louisville, Shawn Stevison (CPA/CHC/CGMA/CRMA) has built a career in healthcare internal audit and compliance services. She currently serves as manager of healthcare consulting services at Dean Dorton Allen Ford, PLLC