On Sunday morning, I attended the session “Compliance in the Post-Acute Environment”. Given that MD Ranger serves an increasing number of these types of organizations, I looked forward to learning more about compliance in this particular space.
The speakers first tackled the tough reality that, while compliance programs for post acute facilities have been mandated by ACA, we still don’t know the specific requirements of these programs. This presentation addressed how compliance officers in the post acute world can “predict” what the OIG and CMS will care about, and structure their compliance program and procedures accordingly.
Overall, it’s safe to say that many elements of an acute care organization’s compliance program translate on the post acute care side of the industry. The speakers emphasized the importance of an easy to understand code of conduct (or compliance policies), as well as a compliance officer that has the resources and authority to do her job. Sanction screening, internal monitoring, enforcement, and measures to address non-compliance were all important elements of post acute compliance programs.
Despite the fact that a lesser number of physicians are involved in post acute care, the speakers took care to mention that a thorough review of your physician contracts is essential to preventing risks like AKB violations or Stark violations. Reviewing agreements with all referral sources can help you document your compliance with federal regulations and ensure that all contracts are fair market value. Integrating physician agreements with your formal compliance program is key. From our perspective at MD Ranger, we couldn’t have said it better ourselves. Because post acute care organizations are so heavily dependent on referrals from key physicians, documentation of FMV becomes even more critical.
Post acute organizations: how do you handle physician contract auditing at your facilities?