An effective compliance plan keeps pace with changing government regulations, payer requirements, office operations, and technology. Compliance plan updates should acknowledge government regulation and payer requirement changes, but should also incorporate lessons from within your own office or facility. Over time, you may find more efficient methods or incorporate new technology to achieve your compliance goals. You can customize your compliance plan to work best for you.
Storing your compliance plan electronically allows for the easiest revision, and also provides the benefit of quick access from any location. Divide the plan into sections or chapters, and create a separate file for each (smaller files are more manageable). Create a new file each time you make a compliance plan revision, but do not write over or erase previous files. You should have a record of past policies to create an “audit trail,” so that you can defend prior claims against the appropriate criteria. Date all files, and archive old files in a separate folder.
If the daily operation of your office or facility doesn’t reflect your compliance plan, you should be concerned. Even an up-to-date compliance plan is no use if staff isn’t aware of it. Education should be a regular, ongoing part of any compliance program. An easy way to keep education current and documented is to scan (or file) the sign in sheet with the educational agenda from each class into the education section of the compliance records, documenting who was trained in what, and when the education took place.
Your compliance plan should be mostly prospective. That is, it should establish effective internal controls to ensure that its coding and documentation practices are in full compliance with the law prior to claims submission. An effective compliance plan also looks back, however. Regular retrospective audits, or review of claims already filed, are valuable to identify coding errors, as well as “high risk” services and providers. This allows you to target education efforts where they are needed, and gives you the opportunity to settle with a payer over past mistakes.