Medicare Compliance & Reimbursement

"Widespread" corporate misconduct sparks a new look at compliance programs.  What the government expects of you when it comes to compliance could undergo a significant overhaul in the near future. An ad hoc committee of the U.S. Sentencing Commission Oct. 7 laid out a slate of recommendations for overhauling the sentencing guidelines that govern corporate misconduct. The move is significant for health care providers because the commission's sentencing guidelines are the basis of the HHS Office of Inspector General's compliance program guidances for health care providers. In sum, the commission suggests putting more emphasis on the effectiveness of corporate compliance efforts. More particularly, the commission recommends:       stressing the inculcation of a "culture" of compliance within an organization; defining "compliance standards and procedures"; spelling out the nature of company leaders' compliance obligations; emphasizing the need to provide compliance officers with adequate resources and authority;   clarifying appropriate practices for employee screening; making training an essential element of an "effective" compliance program (something the OIG already does); mandating that organizations provide a means of anonymous reporting of possible misconduct; adding more language to the guidelines to "specifically encourage prevention and deterrence of violations of the law as part of compliance programs"; and requiring organizations that want credit for having an effective compliance program to conduct "ongoing risk assessments." To see the recommendations, go to http://www.ussc.gov/corp/advgrprpt/advgrprpt.htm.  Lesson Learned: The accounting scandals at Enron, Worldcom and other companies could have a direct effect on health care compliance programs if the government revises its expectations relating to corporate integrity.