Current
OIG's Supplemental Compliance Program Guidance for Hospitals
On January 31, 2005, the HHS Office of Inspector General issued
Supplemental Compliance Program Guidance for Hospitals (70 Federal
Register 4858).
The first
compliance guidance for hospitals was published in 1998. The latest
Guidance does not replace what was issued earlier, but is intended
to supplement it. Together, the two documents offer a set of guidelines
for hospitals to use when developing and implementing a new compliance
program or evaluating an on-going one. The Guidance is a useful
of compendium of relevant laws, regulations, and OIG documents,
and contains a discussion of risk areas -- those places where institutions
may be most likely to encounter problems complying with Federal
requirements -- though few of these should come as a surprise to anyone
who follows the OIG's activities. The document should be thoroughly
reviewed by every institution's compliance officer, and others.
Among the risk areas identified by the OIG that may be of particular
interest to teaching institutions are:
- Improper claims for organ acquisition costs. The Guidance cautions
that "organ acquisition costs are only reimbursable if a
hospital satisfies several requirements, such as having adequate
cost information, supporting documentation, and supporting medical
records." Transplant and post-transplant activities and costs
must not be included in the organ acquisition costs.
- Improper claims for clinical trials. Hospitals should review
the requirements for submitting claims for patients enrolled in
these trials and ensure that billing complies with the rules.
Failure to follow Medicare rules regarding payment for costs related
to educational activities. According to the OIG, hospitals should
pay particular attention to these rules when implementing dental
or other education programs, particularly those not historically
operated at the hospital.
The Guidance also discusses hospital compliance program effectiveness.
Among the recommendations for activities that should occur on
an annual basis are: compliance training of staff; a re-evaluation
of a hospital's training and education program; and a re-evaluation
of the hospital's audit plan, with an emphasis on whether it addresses
proper areas of concern based on findings from previous years'
audits, an annual assessment of risk areas, and high volume services.
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Related Issues
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