Compliance plans have become an important and integral tool in ensuring compliance in the health care industry. Under the Affordable Care Act, compliance plans have become mandated for many Medicare providers. Even for those Medicare provider types for which CMS has not yet issues rules implementing a requirement for a plan, it is clearly a “best practice” to have a meaningful compliance plan in place.
In addition to government requirements for compliance plans, many commercial insurance plans require enrolled providers to have a compliance plan as a condition of enrollment. The absence of a compliance plan can therefore provide a separate basis to terminate a provider if a dispute arises with a commercial payer.
Regardless of the motivation for instituting a compliance plan, having a properly tailored and effective plan is essential. There is no “one size fits all” compliance plan, as each provider is unique in their composition, compliance issues and compliance needs. The attorneys at Nicholson & Eastin, LLP assist our clients in evaluating their compliance needs and in developing an appropriate compliance plan. For those clients with a plan already in place, we can assist with an effectiveness review.
Please do not hesitate to contact us to discuss your compliance plan needs. A properly implemented compliance plan provides valuable compliance insurance that is well worth the investment.