Effective Compliance Program Components
The OIG feels that implementing a compliance program shows that a 
practice is making good faith efforts to submit claims appropriately. They have compiled seven components of an effective compliance program.
* A practice should conduct regular reviews on policies and procedures to ensure they are up-to-date and complete. This benchmarking allows a practice to document the decrease or increase in paid and denied claims. Then, review internal processes to ensure that coding and documentation is being conducted properly.
* Once internal reviews have pinpointed risk areas in a practice, a set of written “practice standards” should be developed and implemented. This will establish tighter internal controls to reduce errors and fraudulent claims.
* A practice should designate a Compliance Officer or contact who will be responsible for developing any corrective measures, if needed, for all compliance related areas.
* Training is an essential element of the Compliance Program. An appropriate education program includes elements of coding, billing, federal statutes, regulations, and aspects of the Program.
* If a practice detects a possible violation, it should determine how to respond to the offense and develop appropriate corrective initiatives. An example of a corrective action is returning any over-payments.
* Establishing open channels of communication between the physicians and compliance personnel helps to eliminate problems from occurring. This can be an informal function, such as the implementation of an “open door” policy.
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