The Proactive Approach

You are in this program because you care about compliance. It is vital that you maintain your level of care throughout this process. Refrain from comparing your practice to a colleague who seems to be successful without a compliance program. It is a risky path and not worth any envy.

Often times a clinic will find themselves in hot water because of ignorance, not knowing what they were doing was illegal. When we did not live in the information society where everything we want to know was at our fingertips we could have gotten away with ignorance and innocence. Now that is not possible as the HHS and OIG have flooded providers with plenty of information. Violations are often classified as willful neglect because there is no excuse for not knowing.

At KMC University we promote the proactive approach rather than the costly alternative of reactive approach. It may seem a bit overwhelming at first, but do not give up or give in. In order for your team to get on the same page, we highly recommend that the compliance contact and the owner operators watch the following three videos provided by the OIG. These quick tutorials will impress on you the importance of implementing your OIG Compliance program and help you identify areas for improvement in the clinic.

What is the Physician Self-Referral Law?

What is the False Claims Act?

What is the Federal Anti-kickback Statute?

Now you are ready to move forward with your first OIG Implementation task.