Each practice should identify the areas where it is most at risk of running afoul of state and federal fraud and abuse laws. In small practices, that is typically in coding and documentation processes. Once these high risk areas are established, the practice must actively monitor activities on an ongoing basis to ensure continuous compliance.
The MedSafe Comprehensive Compliance Audit is a top-to-bottom review of ownership arrangements, certain contracts, employment agreements, policies and procedures to insure that everything is as it should be. This is the kind of audit MedSafe does pre-practice acquisition, and it is the kind of audit every practice should be doing on a periodic basis.
Your Compliance Committee may periodically instruct one or more of your practice's employees to undertake the Auditing and Monitoring of your Compliance Program. All employees are expected to assist and fully cooperate with this effort. From time to time, an organization may also choose to have auditors and investigators from outside our organization involved in the process of reviewing and auditing the effectiveness of your Compliance Program. These auditors and investigators may differ from the persons conducting internal investigations. In addition to investigating specific reports of violations, they may be conducting broad reviews of how the Compliance Program is operating or of specific legal or regulatory compliance. Even though these auditors and investigators may not be investigating a specific violation, it is still absolutely necessary that employees cooperate with their investigations as fully as they would if a violation of the law were at issue.
It is critical that employees play a central role in the Auditing and Monitoring of the Compliance Program. Employees should feel free to express their concerns about the process of training and communication of the Compliance Program, as well as to ask any questions about the Code of Conduct or Compliance Policies. If employees have suggestions as to how an organization can improve its process of communication or the Compliance Program itself, they should let their immediate supervisor or the Compliance Officer know. If employees do not feel comfortable communicating with their supervisor about these issues, they should contact the Compliance Officer directly.
Feedback is of no use unless it reaches the Compliance Committee. Supervisors and managers must ensure that the comments they receive regarding the Compliance Program are routed to the Compliance Committee.