Corporate Compliance & Integrity
General Medicine, P.C. – The Post-Hospitalist Company has always prided itself on its commitment to operating in a legal and ethical manner. As the health care regulatory environment becomes increasingly complex, it is essential that each and every health care provider pledge to comply with all applicable laws and regulations and to achieve the highest ethical and professional standards.
Key elements performed to ensure compliance:
Acuity Analysis and Billing Code Distribution
- ValueScope, Inc. a team of independent statisticians and auditors with extensive experience performing work for CMS, HHS, the IRS, various state agencies and health care providers performed an analysis of 100% of all services provided for eight years. ValueScope determined that there was no pattern of overutilization (the utilization was appropriate) and service frequency correlated closely with patient acuity.
- Additionally, the coding distribution was determined to be consistent with national statistics for coding distribution for similar providers.
- Query the National Practitioner Data Bank website for background information. http://www.npdb.hrsa.gov
- Query both CMS and OIG’s databases for excluded clinicians or entity exclusions.
Post-hire Compliance Training
- The accurate coding and submission of claims for services rendered and/or items provided to Federal health care program beneficiaries
- Applicable reimbursement statutes, regulations and program requirements
- Policies, procedures and other requirements applicable to documentation
- Personal obligation of each person involved in the coding and claims submission process to ensure that claims are accurate
- Legal sanctions for submission of improper claims or violations of the federal health care program requirement
- Medicare fraud and abuse: prevention, detection and reporting.
- Continuing Compliance Education: Each year, all directors, officers, employees, agents, contractors and members of the medical staff are required to successfully complete at least three hours of continuing educational-compliance training.
- Perform both internal and external audits of all services. These audits check for billing accuracy as well as compliance of clinical documentation.
General Medicine, P.C. – The Post- Hospitalist Company’s commitment to corporate compliance, includes a detailed corporate compliance plan. The plan explains the legal and ethical standards that govern all business activities. It provides guidance to employees in reaching legal and ethical solutions to the challenges they face in their daily activities. The plan also informs all employees of the resources in place to ensure compliance with applicable laws and regulations and advises them to report areas of concern. The corporate compliance plan applies to all directors, officers, employees, agents, contractors and members of the medical staff.