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Re: complaince document

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  • tronzo55
    --Thank you for the advise I already looked at the OIG guidelines, and thought that was the case, but I was not sure, thanks for clarifying, I will get to work
    Message 1 of 9 , Jul 1, 2006
      --Thank you for the advise I already looked at the OIG guidelines,
      and thought that was the case, but I was not sure, thanks for
      clarifying, I will get to work

      Theresa

      tmronzo@...

      - In CRN-L@yahoogroups.com, "Pamela Mauerhan" <maverham@...> wrote:
      >
      > Theresa,
      >
      > A compliance document (or several documents, constituting a
      > compliance plan) is not something you want to get from someone
      > else. In order for it to be effective, it has to be written
      > specifically for your practice or business. If you look at the
      > OIG's published guidelines, you will get an idea of what elements
      > are required and/or recommended. Address each one, as it applies
      to
      > your specific situation. That will be a good starting point.
      Then,
      > over time, as certain situations arise, you will need to taylor the
      > existing plan to address the various situations. One thing you
      will
      > have to do is put methods into place (e.g. audits) whereby you
      > uncover additional weaknesses of your existing plan. Those
      > practices that have an instituted written complaince plan will
      > attest to the fact that it is an evolving process, constantly being
      > updated and improved. It is basically an entity in and of itself.
      > It is not just a document that can be shared, as a very small
      > percentage of it would even apply to another practice. That is what
      > comprises a REAL compliance plan as opposed to a few documents that
      > sit on the shelf and get dusted off once in a while by the cleaning
      > crew.
      >
      > Start by listing the elements recommended by the OIG. Address each
      > one, one by one, as it applies to your practice. Start small and
      > add to it as you encounter issues.
      >
      > -Pam
      >
      >
      > --- In CRN-L@yahoogroups.com, "tronzo55" <tmronzo@> wrote:
      > >
      > > Hi Guys
      > >
      > > I am need of a compliance document, I was given the site to look
      > up the info, for which I thank Leah for, but I would like to know
      if
      > anybody has any examples that I can look at to create one, or is
      > there a standard one, I am not very familiar with this at all, and
      > would appreciate any advice I can get.
      > >
      > > Thanks Theresa Ronzo,CPC
      > >
      > > tmronzo@
      > >
      >
    • David D. Marcus
      Theresa, Doesn t the AMA have a model compliance plan that s available to member physicians who can pull it off the web? I think you would probably have a
      Message 2 of 9 , Jul 1, 2006
        Theresa,



        Doesn't the AMA have a model compliance plan that's available to member
        physicians who can pull it off the web? I think you would probably have a
        stronger plan if you begin with the legal expertise that the AMA brings to
        the task. Trying to build a plan around the OIG's published guidelines is a
        big, time-consuming job. Having a model greatly simplifies the job and
        relieves people of having to interpret the OIG's intentions. I don't think
        practices have the time or the money to do a plan from scratch.



        David



        David D. Marcus MBA, PhD

        Physician Payment Resources, LLC

        602 Summerwind Circle

        Nashville, TN 37215

        Voice & Fax: 615.665.9738

        Email: ddmarcus@...



        _____

        From: CRN-L@yahoogroups.com [mailto:CRN-L@yahoogroups.com] On Behalf Of
        Pamela Mauerhan
        Sent: Friday, June 30, 2006 7:58 PM
        To: CRN-L@yahoogroups.com
        Subject: [CRN-L] Re: complaince document



        Theresa,

        A compliance document (or several documents, constituting a
        compliance plan) is not something you want to get from someone
        else. In order for it to be effective, it has to be written
        specifically for your practice or business. If you look at the
        OIG's published guidelines, you will get an idea of what elements
        are required and/or recommended. Address each one, as it applies to
        your specific situation. That will be a good starting point. Then,
        over time, as certain situations arise, you will need to taylor the
        existing plan to address the various situations. One thing you will
        have to do is put methods into place (e.g. audits) whereby you
        uncover additional weaknesses of your existing plan. Those
        practices that have an instituted written complaince plan will
        attest to the fact that it is an evolving process, constantly being
        updated and improved. It is basically an entity in and of itself.
        It is not just a document that can be shared, as a very small
        percentage of it would even apply to another practice. That is what
        comprises a REAL compliance plan as opposed to a few documents that
        sit on the shelf and get dusted off once in a while by the cleaning
        crew.

        Start by listing the elements recommended by the OIG. Address each
        one, one by one, as it applies to your practice. Start small and
        add to it as you encounter issues.

        -Pam

        --- In CRN-L@yahoogroups. <mailto:CRN-L%40yahoogroups.com> com, "tronzo55"
        <tmronzo@...> wrote:
        >
        > Hi Guys
        >
        > I am need of a compliance document, I was given the site to look
        up the info, for which I thank Leah for, but I would like to know if
        anybody has any examples that I can look at to create one, or is
        there a standard one, I am not very familiar with this at all, and
        would appreciate any advice I can get.
        >
        > Thanks Theresa Ronzo,CPC
        >
        > tmronzo@...
        >





        [Non-text portions of this message have been removed]
      • Leslie
        You re so right. I took the OIG model compliance plan & tailored it to my company ... and it took me roughly around 50-60 hours to do - and it was just about
        Message 3 of 9 , Jul 1, 2006
          You're so right.

          I took the OIG model compliance plan & tailored it to my company ...
          and it took me roughly around 50-60 hours to do - and it was just
          about the coding; I hadn't even gotten into the billing side yet.

          What really got me is that they never even used it (I'm not there
          anymore). UGH!

          Leslie

          --- In CRN-L@yahoogroups.com, "David D. Marcus" <ddmarcus@...> wrote:
          >
          > Theresa,
          >
          >
          >
          > Doesn't the AMA have a model compliance plan that's available to
          member
          > physicians who can pull it off the web? I think you would
          probably have a
          > stronger plan if you begin with the legal expertise that the AMA
          brings to
          > the task. Trying to build a plan around the OIG's published
          guidelines is a
          > big, time-consuming job. Having a model greatly simplifies the
          job and
          > relieves people of having to interpret the OIG's intentions. I
          don't think
          > practices have the time or the money to do a plan from scratch.
          >
          >
          >
          > David
          >
          >
          >
          > David D. Marcus MBA, PhD
          >
          > Physician Payment Resources, LLC
          >
          > 602 Summerwind Circle
          >
          > Nashville, TN 37215
          >
          > Voice & Fax: 615.665.9738
          >
          > Email: ddmarcus@...
          >
          >
          >
          > _____
          >
          > From: CRN-L@yahoogroups.com [mailto:CRN-L@yahoogroups.com] On
          Behalf Of
          > Pamela Mauerhan
          > Sent: Friday, June 30, 2006 7:58 PM
          > To: CRN-L@yahoogroups.com
          > Subject: [CRN-L] Re: complaince document
          >
          >
          >
          > Theresa,
          >
          > A compliance document (or several documents, constituting a
          > compliance plan) is not something you want to get from someone
          > else. In order for it to be effective, it has to be written
          > specifically for your practice or business. If you look at the
          > OIG's published guidelines, you will get an idea of what elements
          > are required and/or recommended. Address each one, as it applies
          to
          > your specific situation. That will be a good starting point. Then,
          > over time, as certain situations arise, you will need to taylor
          the
          > existing plan to address the various situations. One thing you
          will
          > have to do is put methods into place (e.g. audits) whereby you
          > uncover additional weaknesses of your existing plan. Those
          > practices that have an instituted written complaince plan will
          > attest to the fact that it is an evolving process, constantly
          being
          > updated and improved. It is basically an entity in and of itself.
          > It is not just a document that can be shared, as a very small
          > percentage of it would even apply to another practice. That is
          what
          > comprises a REAL compliance plan as opposed to a few documents
          that
          > sit on the shelf and get dusted off once in a while by the
          cleaning
          > crew.
          >
          > Start by listing the elements recommended by the OIG. Address each
          > one, one by one, as it applies to your practice. Start small and
          > add to it as you encounter issues.
          >
          > -Pam
          >
          > --- In CRN-L@yahoogroups. <mailto:CRN-L%40yahoogroups.com>
          com, "tronzo55"
          > <tmronzo@> wrote:
          > >
          > > Hi Guys
          > >
          > > I am need of a compliance document, I was given the site to look
          > up the info, for which I thank Leah for, but I would like to know
          if
          > anybody has any examples that I can look at to create one, or is
          > there a standard one, I am not very familiar with this at all, and
          > would appreciate any advice I can get.
          > >
          > > Thanks Theresa Ronzo,CPC
          > >
          > > tmronzo@
          > >
          >
          >
          >
          >
          >
          > [Non-text portions of this message have been removed]
          >
        • Leah
          To be honest, I ve had that thing sitting around forever, and never actually gave it a good luck until Teresa s post. I see now what everyone is talking about
          Message 4 of 9 , Jul 1, 2006
            To be honest, I've had that thing sitting around forever, and never actually
            gave it a good luck until Teresa's post. I see now what everyone is talking
            about - I always assumed it was exactly what it was purported to be - a
            MODEL - it's not! I agree that a tailorable model would be much more useful
            to starting at ground zero - then using the compliance guideline to make
            sure your first draft is sufficient.

            Leah

            -----Original Message-----
            From: CRN-L@yahoogroups.com [mailto:CRN-L@yahoogroups.com]On Behalf Of
            Leslie
            Sent: Saturday, July 01, 2006 11:40 AM
            To: CRN-L@yahoogroups.com
            Subject: [CRN-L] Re: complaince document


            You're so right.

            I took the OIG model compliance plan & tailored it to my company ...
            and it took me roughly around 50-60 hours to do - and it was just
            about the coding; I hadn't even gotten into the billing side yet.

            What really got me is that they never even used it (I'm not there
            anymore). UGH!

            Leslie

            --- In CRN-L@yahoogroups.com, "David D. Marcus" <ddmarcus@...> wrote:
            >
            > Theresa,
            >
            >
            >
            > Doesn't the AMA have a model compliance plan that's available to
            member
            > physicians who can pull it off the web? I think you would
            probably have a
            > stronger plan if you begin with the legal expertise that the AMA
            brings to
            > the task. Trying to build a plan around the OIG's published
            guidelines is a
            > big, time-consuming job. Having a model greatly simplifies the
            job and
            > relieves people of having to interpret the OIG's intentions. I
            don't think
            > practices have the time or the money to do a plan from scratch.
            >
            >
            >
            > David
            >
            >
            >
            > David D. Marcus MBA, PhD
            >
            > Physician Payment Resources, LLC
            >
            > 602 Summerwind Circle
            >
            > Nashville, TN 37215
            >
            > Voice & Fax: 615.665.9738
            >
            > Email: ddmarcus@...
            >
            >
            >
            > _____
            >
            > From: CRN-L@yahoogroups.com [mailto:CRN-L@yahoogroups.com] On
            Behalf Of
            > Pamela Mauerhan
            > Sent: Friday, June 30, 2006 7:58 PM
            > To: CRN-L@yahoogroups.com
            > Subject: [CRN-L] Re: complaince document
            >
            >
            >
            > Theresa,
            >
            > A compliance document (or several documents, constituting a
            > compliance plan) is not something you want to get from someone
            > else. In order for it to be effective, it has to be written
            > specifically for your practice or business. If you look at the
            > OIG's published guidelines, you will get an idea of what elements
            > are required and/or recommended. Address each one, as it applies
            to
            > your specific situation. That will be a good starting point. Then,
            > over time, as certain situations arise, you will need to taylor
            the
            > existing plan to address the various situations. One thing you
            will
            > have to do is put methods into place (e.g. audits) whereby you
            > uncover additional weaknesses of your existing plan. Those
            > practices that have an instituted written complaince plan will
            > attest to the fact that it is an evolving process, constantly
            being
            > updated and improved. It is basically an entity in and of itself.
            > It is not just a document that can be shared, as a very small
            > percentage of it would even apply to another practice. That is
            what
            > comprises a REAL compliance plan as opposed to a few documents
            that
            > sit on the shelf and get dusted off once in a while by the
            cleaning
            > crew.
            >
            > Start by listing the elements recommended by the OIG. Address each
            > one, one by one, as it applies to your practice. Start small and
            > add to it as you encounter issues.
            >
            > -Pam
            >
            > --- In CRN-L@yahoogroups. <mailto:CRN-L%40yahoogroups.com>
            com, "tronzo55"
            > <tmronzo@> wrote:
            > >
            > > Hi Guys
            > >
            > > I am need of a compliance document, I was given the site to look
            > up the info, for which I thank Leah for, but I would like to know
            if
            > anybody has any examples that I can look at to create one, or is
            > there a standard one, I am not very familiar with this at all, and
            > would appreciate any advice I can get.
            > >
            > > Thanks Theresa Ronzo,CPC
            > >
            > > tmronzo@
            > >
            >
            >
            >
            >
            >
            > [Non-text portions of this message have been removed]
            >






            [Non-text portions of this message have been removed]
          • Charlotte L. Kohler
            we have one on our old web site: www.KHC.com ... Charlotte L. Kohler, CPA, RN, CVA, CPAM, CPC NEW E-mail address: CKohler@Navigantconsulting.com Navigant
            Message 5 of 9 , Jul 4, 2006
              we have one on our old web site: www.KHC.com

              At 10:18 PM 6/30/06 +0000, you wrote:
              >Hi Guys
              >
              >I am need of a compliance document, I was given the site to look up the
              >info, for which I thank Leah for, but I would like to know if anybody
              >has any examples that I can look at to create one, or is there a
              >standard one, I am not very familiar with this at all, and would
              >appreciate any advice I can get.
              >
              >Thanks Theresa Ronzo,CPC
              >
              >tmronzo@...
              >
              >
              >
              >
              >
              >
              >http://www.codingandreimbursement.net
              >
              >Yahoo! Groups Links
              >
              >
              >
              >

              Charlotte L. Kohler, CPA, RN, CVA, CPAM, CPC
              NEW E-mail address: CKohler@...
              Navigant Consulting
              Assessments -- Valuations -- Compliance
              Direct (cell): 443/956-1434
              Baltimore Office and voice mail: 410/454-6204
              Fax 410/454-6201
              secondary office: 410/461-5116
              Fax - secondary office: 410/461-5117
              Member: Society Of Medical Dental Consultants
              AMA Consulting Link
              e-mail: CKohler@...
              Check out our WebSite at www.NavigantConsulting.com and
              www.KohlerHealthcare.com

              "This transmitted information is intended only for the person or entity to
              which it is addressed and may contain confidential and/or privileged
              material. Any review, retransmission, dissemination or other use of, or
              taking of any action in reliance upon, this information by persons or
              entities other than the intended recipient is prohibited. If you received
              this in error, please contact the sender and delete the material from any
              computer"





              [Non-text portions of this message have been removed]
            • Dianne Wilkinson
              Leah, I don t know if it s still available on the ACR web site, but the radiologists came up with an excellent compliance plan model a few years back that I
              Message 6 of 9 , Jul 5, 2006
                Leah, I don't know if it's still available on the ACR web site, but the
                radiologists came up with an excellent compliance plan model a few years
                back that I have used often. It is succinct and easy to work from, but
                contains all the important elements. I hope it's still there...I've seen
                longer ones, but none that were better. Good luck! Dianne.

                -----Original Message-----
                From: CRN-L@yahoogroups.com [mailto:CRN-L@yahoogroups.com] On Behalf Of Leah
                Sent: Saturday, July 01, 2006 12:09 PM
                To: CRN-L@yahoogroups.com
                Subject: RE: [CRN-L] Re: complaince document

                To be honest, I've had that thing sitting around forever, and never actually
                gave it a good luck until Teresa's post. I see now what everyone is talking
                about - I always assumed it was exactly what it was purported to be - a
                MODEL - it's not! I agree that a tailorable model would be much more useful
                to starting at ground zero - then using the compliance guideline to make
                sure your first draft is sufficient.

                Leah

                -----Original Message-----
                From: CRN-L@yahoogroups.com [mailto:CRN-L@yahoogroups.com]On Behalf Of
                Leslie
                Sent: Saturday, July 01, 2006 11:40 AM
                To: CRN-L@yahoogroups.com
                Subject: [CRN-L] Re: complaince document


                You're so right.

                I took the OIG model compliance plan & tailored it to my company ...
                and it took me roughly around 50-60 hours to do - and it was just
                about the coding; I hadn't even gotten into the billing side yet.

                What really got me is that they never even used it (I'm not there
                anymore). UGH!

                Leslie

                --- In CRN-L@yahoogroups.com, "David D. Marcus" <ddmarcus@...> wrote:
                >
                > Theresa,
                >
                >
                >
                > Doesn't the AMA have a model compliance plan that's available to
                member
                > physicians who can pull it off the web? I think you would
                probably have a
                > stronger plan if you begin with the legal expertise that the AMA
                brings to
                > the task. Trying to build a plan around the OIG's published
                guidelines is a
                > big, time-consuming job. Having a model greatly simplifies the
                job and
                > relieves people of having to interpret the OIG's intentions. I
                don't think
                > practices have the time or the money to do a plan from scratch.
                >
                >
                >
                > David
                >
                >
                >
                > David D. Marcus MBA, PhD
                >
                > Physician Payment Resources, LLC
                >
                > 602 Summerwind Circle
                >
                > Nashville, TN 37215
                >
                > Voice & Fax: 615.665.9738
                >
                > Email: ddmarcus@...
                >
                >
                >
                > _____
                >
                > From: CRN-L@yahoogroups.com [mailto:CRN-L@yahoogroups.com] On
                Behalf Of
                > Pamela Mauerhan
                > Sent: Friday, June 30, 2006 7:58 PM
                > To: CRN-L@yahoogroups.com
                > Subject: [CRN-L] Re: complaince document
                >
                >
                >
                > Theresa,
                >
                > A compliance document (or several documents, constituting a
                > compliance plan) is not something you want to get from someone
                > else. In order for it to be effective, it has to be written
                > specifically for your practice or business. If you look at the
                > OIG's published guidelines, you will get an idea of what elements
                > are required and/or recommended. Address each one, as it applies
                to
                > your specific situation. That will be a good starting point. Then,
                > over time, as certain situations arise, you will need to taylor
                the
                > existing plan to address the various situations. One thing you
                will
                > have to do is put methods into place (e.g. audits) whereby you
                > uncover additional weaknesses of your existing plan. Those
                > practices that have an instituted written complaince plan will
                > attest to the fact that it is an evolving process, constantly
                being
                > updated and improved. It is basically an entity in and of itself.
                > It is not just a document that can be shared, as a very small
                > percentage of it would even apply to another practice. That is
                what
                > comprises a REAL compliance plan as opposed to a few documents
                that
                > sit on the shelf and get dusted off once in a while by the
                cleaning
                > crew.
                >
                > Start by listing the elements recommended by the OIG. Address each
                > one, one by one, as it applies to your practice. Start small and
                > add to it as you encounter issues.
                >
                > -Pam
                >
                > --- In CRN-L@yahoogroups. <mailto:CRN-L%40yahoogroups.com>
                com, "tronzo55"
                > <tmronzo@> wrote:
                > >
                > > Hi Guys
                > >
                > > I am need of a compliance document, I was given the site to look
                > up the info, for which I thank Leah for, but I would like to know
                if
                > anybody has any examples that I can look at to create one, or is
                > there a standard one, I am not very familiar with this at all, and
                > would appreciate any advice I can get.
                > >
                > > Thanks Theresa Ronzo,CPC
                > >
                > > tmronzo@
                > >
                >
                >
                >
                >
                >
                > [Non-text portions of this message have been removed]
                >






                [Non-text portions of this message have been removed]



                http://www.codingandreimbursement.net

                Yahoo! Groups Links







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              • Dianne Wilkinson
                One more comment about designing a compliance plan...a suggestion from my old Quality Assurance days in the hospital. The risk areas identified in the OIG
                Message 7 of 9 , Jul 5, 2006
                  One more comment about designing a compliance plan...a suggestion from my
                  old Quality Assurance days in the hospital. The risk areas identified in
                  the OIG compliance guidance is obviously where you want to start with
                  auditing and monitoring; but since you don't have the resources to monitor
                  all of them all the time, the Joint Commission had a great way to "triage"
                  what to monitor by way of priority...they said you need to focus on the
                  things in your organization that are (1) high volume (2) high risk (3)
                  problem prone. The "problem prone" is a really good one. What might be
                  causing you mega denials in your Practice might not be causing ANY for the
                  folks down the street. If your Dexascan machine is turning them out at huge
                  volume, it would be a good idea to be sure they were all medically necessary
                  and documented as such. Just a thought...Dianne.

                  -----Original Message-----
                  From: CRN-L@yahoogroups.com [mailto:CRN-L@yahoogroups.com] On Behalf Of
                  Pamela Mauerhan
                  Sent: Friday, June 30, 2006 7:58 PM
                  To: CRN-L@yahoogroups.com
                  Subject: [CRN-L] Re: complaince document

                  Theresa,

                  A compliance document (or several documents, constituting a
                  compliance plan) is not something you want to get from someone
                  else. In order for it to be effective, it has to be written
                  specifically for your practice or business. If you look at the
                  OIG's published guidelines, you will get an idea of what elements
                  are required and/or recommended. Address each one, as it applies to
                  your specific situation. That will be a good starting point. Then,
                  over time, as certain situations arise, you will need to taylor the
                  existing plan to address the various situations. One thing you will
                  have to do is put methods into place (e.g. audits) whereby you
                  uncover additional weaknesses of your existing plan. Those
                  practices that have an instituted written complaince plan will
                  attest to the fact that it is an evolving process, constantly being
                  updated and improved. It is basically an entity in and of itself.
                  It is not just a document that can be shared, as a very small
                  percentage of it would even apply to another practice. That is what
                  comprises a REAL compliance plan as opposed to a few documents that
                  sit on the shelf and get dusted off once in a while by the cleaning
                  crew.

                  Start by listing the elements recommended by the OIG. Address each
                  one, one by one, as it applies to your practice. Start small and
                  add to it as you encounter issues.

                  -Pam


                  --- In CRN-L@yahoogroups.com, "tronzo55" <tmronzo@...> wrote:
                  >
                  > Hi Guys
                  >
                  > I am need of a compliance document, I was given the site to look
                  up the info, for which I thank Leah for, but I would like to know if
                  anybody has any examples that I can look at to create one, or is
                  there a standard one, I am not very familiar with this at all, and
                  would appreciate any advice I can get.
                  >
                  > Thanks Theresa Ronzo,CPC
                  >
                  > tmronzo@...
                  >







                  http://www.codingandreimbursement.net

                  Yahoo! Groups Links








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