Background:

The Office of Inspector General (OIG) of the Department of Health and Human Services established compliance program guidelines for individual and small‐group physician practices and for hospitals. Although having a formal compliance plan was labeled “voluntary,” not having one increases a practice's vulnerability to fines and penalties as a consequence of federal billing audits, whereas the establishment of an effective compliance program significantly reduces the risk of unlawful or improper conduct.

Our hospitalist program's administrative team created and implemented a compliance program uniquely suited to our practice by integrating the OIG's Compliance Program for Individual and Small Group Physician Practices with the hospital's existing compliance program.

Purpose:

Our purpose is to describe the development and implementation of a hospital medicine compliance program in a community, nonteaching hospitalist program.

Description:

Our compliance plan was based on and includes the OIG's 7 elements for physician compliance program development:

  • 1.

    Conducting internal monitoring and auditing;

  • 2.

    Implementing compliance and practice standards;

  • 3.

    Designating a compliance officer or contact;

  • 4.

    Conducting appropriate training and education;

  • 5.

    Responding appropriately to detected offenses and developing corrective action;

  • 6.

    Developing open lines of communication; and

  • 7.

    Enforcing disciplinary standards through well‐publicized guidelines.

Information from the federal registry and external resources was used to develop our hospitalist practice's compliance plan and program. Hospitalist team member input was obtained during team meetings and incorporated into the program.

A coding curve calculator was initially used to determine how our team compared to Medicare's benchmarkfor general internists (hospitalist data unavailable) to identify variances that would guide our early audit efforts. Chart audits are conducted on a quarterly basis and are based on results of prior audits, areas identified for improvement or maintenance, new team member baseline determination and follow‐up, current topics in the news, team requests, and/or according to plan delineation.

Compliance is a standing agenda item at our monthly team meeting for education and review of audit results, is covered in an annual compliance review with pre‐ and posttest measurements, and is part of new employee orientation.

Conclusions:

Our compliance program provides ongoing guidance and direction to our team's compliance efforts, ensuring that our performance remains reliable and our conduct consistent.

A successful compliance program helps to reduce fraud and abuse, enhances daily operations, improves the quality and reduces the overall cost of health care services.

Author Disclosure:

M. Wilson, None; S. Blue, None; R. Williams, None; C. Kendrick, None; M. Medford, None.