Anesthesia Compliance Consultants

Providing compliance education and services
to anesthesia providers, hospitals and billing companies

Compliance and HIPAA Training

We specialize in providing Anesthesia Compliance and HIPAA training to anesthesia professionals using our web-based education platform. Choose from the courses listed below or allow us to create a program tailored specifically to your organization, type of practice or company.

We offer the following courses in an online setting:

  • Anesthesia Compliance
  • Anesthesia HIPAA Privacy
  • Anesthesia Compliance and Privacy
  • Anesthesia Evaluation and Management Coding
  • Fraud, Waste and Abuse Training

We provide online group training. We will educate your company on anesthesia compliance and HIPAA Privacy. Contact us for more information and group rates.

Compliance Plans

ACC will assist with the creation of a compliance plan for your organization. Our team of experienced professionals crafts compliance plans consistent with regulatory, medical, billing and coding standards.

“We understand anesthesia: we have stood in your shoes.”

Latest News

The Exclusion Statute

Posted on Jul 25, 2019 in Medicare Compliance, Medicare Fraud

Your Anesthesia Compliance Tip for today is on the

Exclusion Statute:

First we must focus on Mandatory exclusions:

These are exclusion by which the OIG is required by law to exclude from participation in all Federal health care programs individuals convicted of the following types of criminal offenses:

  1. Medicare or Medicaid fraud, or any offenses related to the delivery of services under Medicare, Medicaid, or State programs;
  2. patient abuse or neglect;
  3. felony convictions for health care-related fraud, theft, or other financial misconduct; and
  4. felony convictions relating to unlawful manufacture, distribution, prescription, or dispensing of controlled substances.

 Secondly there are Permissive exclusions:

In which the OIG has discretion to exclude individuals and entities on a number of grounds,

  1. including misdemeanor convictions related to health care fraud other than Medicare or a State health program,
  2. fraud in a program funded by any Federal, State or local government agency;
  3. misdemeanor convictions relating to the unlawful manufacture, distribution, prescription, or dispensing of controlled substances;
  4. suspension, revocation, or surrender of a license to provide health care for reasons bearing on professional competence, professional performance, or financial integrity;
  5. provision of unnecessary or substandard services;
  6. submission of false or fraudulent claims to a Federal health care program;
  7. engaging in unlawful kickback arrangements;
  8. defaulting on health education loan or scholarship obligations; and controlling a sanctioned entity as an owner, officer, or managing employee.

To avoid Civil Monetary Penalty liability, health care entities need to routinely check the (LEIE) List of Excluded Individuals and Entities to ensure that new hires and current employees are not on the excluded list.

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The Anti-Kickback Statute

Posted on Jun 24, 2019 in Billing, Medicare Compliance, Medicare Fraud


A Criminal Law

The Anti-Kickback Statute is a criminal law that prohibits the knowing and willful payment or “remuneration” to induce or reward patient referrals.  It also applies to  the generation of business involving any item or service payable by the Federal health care programs. Remuneration includes anything of value and can take many forms besides cash, such as free rent, expensive hotel stays and meals, and excessive compensation for medical directorships or consultancies.


Criminal penalties and administrative sanctions for violating the Anti-Kickback Statute include fines, jail terms, and exclusion from participation in the Federal health care programs. Under this law, physicians who pay or accept kickbacksalso face penalties of up to $50,000 per kickback plus three times the amount of the remuneration.

Target for Kickbacks

As a physician, you are an attractive target for kickback schemes because you can be a source of referrals for fellow physicians or other health care providers and suppliers. You decide what drugs your patients use, which specialists they see, and what health care services and supplies they receive.

Just as it is illegal for you to take money from providers and suppliers in return for the referral of your Medicare and Medicaid patients, it is illegal for you to pay others to refer their Medicare and Medicaid patients to you.

Contact us for more information on these important topics and anesthesia compliance training for you and your company.

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Technical Safeguards

Posted on Jun 19, 2019 in HIPAA


Technical safeguards are important due to technology advancements in the health care industry. Healthcare organizations are faced with the challenge of protecting electronic protected health information (EPHI), such as electronic health records, from various internal and external risks.

Covered Entity Must Comply

It is important, and therefore required by the Security Rule, for a covered entity to comply with the Technical Safeguard standards and certain implementation specifications; a covered entity may use any security measures that allow it to reasonably and appropriately do so.

Define “Technical Safeguards”

The Security Rule defines technical safeguards as “the technology and the policy and procedures for its use that protect electronic protected health information and control access to it.” It is based on the fundamental concepts of flexibility, scalability and technology neutrality. Therefore, no specific requirements for types of technology to implement are identified.

Implementing “The Rule”

The Rule allows the use of security measures that allows it reasonably and appropriately to implement the standards and implementation specifications.  A covered entity must determine which security measures and specific technologies are reasonable and appropriate for implementation in its organization.

Read more about Technical Safeguards

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False Claims Act and Anesthesia

Posted on Jun 5, 2019 in Billing, Compliance, Medicare Compliance

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An Important Law

There are many federal laws in place that govern Medicare fraud and abuse. One of the most important laws that addresses fraud is the Federal False Claims Act.    It allows private citizens to bring civil actions on behalf of the United States.

The False Claims Act protects the Federal Government from being overcharged or sold substandard goods or services and imposes civil liability on any person who knowingly submits, or causes the submission of, a false or fraudulent claim to the Federal Government.

Knowledge of Wrongdoing

The terms “knowing” and “knowingly” mean a person has actual knowledge of the information or acts in deliberate ignorance or reckless disregard of the truth or falsity of the information related to the claim. No proof of specific intent to defraud is required to violate the False Claims Act.

Lack of Compliance Plan

Lack of a compliance plan increases the threat of Qui tam lawsuits.  This act provides significant financial incentives for private citizens to come forward as whistleblowers.

This is a law that cannot be taken lightly.  Anesthesia providers should be prepared with an active compliance plan.

Contact us for more information on these important topics and anesthesia compliance training for you and your company.  ACC Contact Us

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New Penalties

Posted on May 13, 2019 in Billing, HIPAA

New Reduced Penalties

The Department of Health and Human Services has published a notice on April 30th that it is exercising its discretion in how it applies its regulations on the assessment of Civil Monetary Penalties (CMPs) under HIPAA. Currently HHS applied the same cumulative annual limit to the four categories of violations.

Pending further rule making HHS will now apply different cumulative annual CMP limits instead of the maximum $1.5 million for each level of violation. This is a reduction in the maximum limit, scaling down based on the level of culpability. HHS will use the new penalty structure until further notice.

Four Categories

Based on four categories of culpability:

For a category of no knowledge the minimum penalty is now $100, and the annual limit will be $25,000 down from $1.5 million.

For a reasonable cause $1,000 is the minimum and $100,000 for an annual limit down from $1.5 million.

For Willful neglect with a correction it would be $10,000 as a minimum and $250,000 for annual limit.

The highest is for Willful neglect with no correction with $50,000 as a minimum with an annual limit of $1,500,000.

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