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You should periodically review your own bills and medical records to make sure that you know what is leaving your office under your signature. Please remember, that when you sign an insurance form electronically or otherwise, you are certifying what is above your signature is true. Whenever possible, please have one provider review the other’s records and bills. This will use a set of “fresh eyes” on the records. Again, document what is occurring. Since 2005, all Medicaid providers that make at least $5 million annually, are required to have a written compliance program. It is beyond the scope of this article to go into the details of what is required in that document. Suffice it to say that the policy must include detailed provisions as to how your practice prevents fraud, waste, and abuse. It is recommended, but not required that all practices have this written policy. Having a written policy that is used in your practice, goes a long way in showing proof to investigating agencies that there is no criminal intent. Of course, the written policy without actual application, is as meaningless as purchasing a compliance plan and leaving it in the original wrapper. The U.S. Department of Health and Human Services has a webpage for such voluntary compliance programs. It can be found at: https://oig.hhs.gov/compliance/physician-education/compliance-programs-for-physicians/

Until next week,

Larry Kobak
Lawrence F. Kobak, Esq.
Senior Counsel
LKobak@frierlevitt.com
516-410-2835
Frier Levitt
ATTORNEYS AT LAW