1. Make compliance plans a priority now.  The new regulations are expected be finalized by the end of this year.  Have your compliance plan in place early so that your office is ready when the regulations take affect.
2. Designate a staff member or team responsible for compliance.  OIG and CMS urge you to have someone designated for implementation of your compliance program.  You can outsource this responsibility to a consultant, if your office cannot afford a full time compliance member.
3. Know risk areas.  The primary areas of concern in the office are documentation, coding, billing, marketing, and financial arrangements. 
4. Manage your financial arrangements. Business relationships and financial arrangements are an area where doctors are likely to run afoul of the new regulations.
5. Educate your employees.  Hold regular staff meetings to keep your employees educated about changes in regulations and your office policies.  If you don’t educate your employees, they may put your office at risk with even knowing.
6. Carry a message of compliance from top to bottom.  It is your office and you need to set an example for your staff. Educate, lead, and support your entire office toward compliance of the new regulations.
7. Conduct audits.  Self-monitoring and audits are an effective way to ensure compliance.  Contract with a certified consultant to audit your office and staff for compliance.
8. Just because your competitor is doing something doesn’t mean that you can or should. Call 1-800-HSS-TIPS to report suspect practices.  OIG urges every doctor to report any infractions of which you become aware.  If everyone helps to enforce compliance, then everyone will benefit.
9. Open lines of communication. Communication is a key in every office compliance plan.  Everyone, from the decision maker to office staff needs to be aware of policies and procedures.  Two way communication will help to create and maintain office compliance.
10. When in doubt, ask for help.  HHS and private consultants are available to assist you in implementing and monitoring your compliance plan.  Take advantage of this help and ask questions when you have any doubt.

          The CMS and OIG are serious about trying to eliminate waste, fraud, and abuse within the Medicare/Medicaid programs, as they should.  Making the programs more efficient will maximize the dollars within the programs going to provide medical care for the recipients.

     I do have to question two aspects of HEAT.  Adding another government bureaucracy to oversee the Medicare/Medicaid programs will necessarily drain dollars from medical care for program recipients.  The only way that adding fraud police will save HHS money is to deny more claims by healthcare providers than the cost of the additional salaries of the oversight agents.  But even if they can accomplish this, it does not mean that more dollars will be available for health care.

     Maybe I’m naive, but I find it hard to believe that there are billions of dollars of fraud being committed by healthcare providers. I know my office doesn’t bill for unnecessary services or procedures which aren’t performed.  I also don’t like the fact that a toll free number is provided to report any suspected fraud or abuse of the system.  The government wants us to turn in fellow professionals, assuming that fraud and abuse are so invasive within the system.  This smacks of Big Brother, and creates mistrust among colleagues, and I simply refuse to operate under the government’s premise that all healthcare providers are out to game the system.  Healthcare professionals are ethical professionals, not politicians.