Anesthesia Compliance Plans; Seven Keys to Success

The complexity of federal and state programs make a compliance program essential for all group practices. Your compliance plan implemented well and maintained through regular meetings and communications is your main line of defense, should your group become the focus of an audit. Without a compliance plan, you will be at the mercy of the payers and should expect huge penalties, potential revocation of Medicare provider certification and even jail time. There is no reason to take the associated risk. Consider compliance a regular part of doing business and invest the energy and resources required to sleep well at night knowing that your risk has been reduced.

 Seven Keys to Compliance Success

1. Internal monitoring and auditing needs to be performed on a scheduled basis by well trained and experienced auditors.
2. There should be clearly written and well communicated compliance program and practice standards.
3. Designate a compliance officer.
4. Maintain a high quality training and education program for all staff members.
5. Insure that the lines of communications are open and allow concerned employees to speak freely, without fear of reprisals.
6.  If a problem is identified, have a plan of action to investigate, and take corrective action if required.
7. Enforce the compliance plan without exception.

 Anesthesiologists should be aware of areas that will draw attention from governmental payers and Recovery Audit Contractors (RACs). Facet injections have been the subject of recent OIG reports. Anesthesia start and stop times and protocol for transfer of care have received recent attention from governmental payers also.