Compliance Program Update for Physician Practices

In September 1999, the Office of Inspector General (“OIG”) published a notice in the “Federal Register” announcing that it was considering developing compliance program guidelines for small physician groups and that it welcomed comments from interested parties. The OIG has already developed specific guidelines for hospitals, clinical laboratories, home health agencies, third-party medical billing companies and durable medical equipment companies. Many physician practices have appropriately developed and implemented compliance programs which utilize the medical billing company compliance guidelines, as those guidelines most closely reflect the relevant issues of submission of Medicare claims.

The OIG has now announced that it is developing compliance program guidelines for individual and small physician practices. The OIG hopes to release this set of proposed compliance guidelines by March 2000 and final guidelines by June 2000.

Concurrently, President Clinton has also announced that the FY 2001 budget proposes an additional $48 million annually to finance efforts to reduce non-compliance in the healthcare system. The President announced that “Financial Management Specialists” would be placed within every Medicare carrier and fiscal intermediary and tasked with reducing incidents of non-compliance by providers.

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