Compliance Plans for Anesthesia

Anesthesia Practices & Compliance

Is your organization prepared for the recommendations on compliance by the Office of Inspector General?    Do you have a compliance plan with policies and procedures?  If you do, have you recently reviewed your compliance plan, policies and procedures?  We can help you prepare the appropriate compliance plans for anesthesia. When we are engaged to consult on your compliance program we will review and revise your plan to assure compliance with federal guidelines and best practices. Moreover, if you don’t have a compliance plan, we will draft a plan with policies and procedures that offers complete coverage of federal guidelines.    We have helped numerous organizations with these concerns.

Why Compliance is Important

Having a compliance plan is important for many reasons but the most important is that it is required by law.  It is the best way of preventing erroneous billing and fraudulent claims.  It will also help you in the case of a potential audit and help prevent enormous legal expenses.  The Federal Sentencing Guidelines explicitly reward the adoption of an “effective” compliance program by reducing the imposed sanctions.  For years the Office of Inspector General (OIG) has encouraged providers to implement compliance programs.  They have also indicated providers who lack programs risk more severe sanctions if penalties are given.

Since 1976, the Department of Health and Human Services Office of inspector General (HHS-OIG) has been working to prevent fraud, waste and abuse in federally funded healthcare programs.  These include Medicare, Medicaid and the Children’s Health Insurance Program (CHIP).  HHS- OIG’s focus is to protect the integrity of HHS programs as well as the health and welfare of program beneficiaries.

Compliance is Mandatory

Initially HHS-OIG published voluntary compliance guidance for individual and small group healthcare practices.  Once the Patient Protection and Affordable Care Act (ACA) went into effect in 2010 compliance programs became mandatory.  Section 6401 of the ACA stipulated that healthcare providers must establish compliance programs as a condition of participation in Medicare, Medicaid and/or the Children’s Health Insurance Program (CHIP).

Compliance Elements

The OIG has identified 7 fundamental elements for an effective compliance program.  These are as follows:

  • Conduct internal monitoring and auditing
  • Implement compliance and practice standards
  • Designate a compliance officer or contact
  • Conduct appropriate training and education
  • Respond appropriately to detected offenses and develop corrective action
  • Develop open lines of communication 
  • Enforce disciplinary standard through well-publicized guidelines

Anesthesia Compliance Consultants will assist your organization to develop a comprehensive Compliance Plan that covers the seven components.  The plan will be created to be consistent with the needs of the anesthesia practice. The plan will satisfy federal and state guidelines, laws and regulations.  If you have a compliance plan in place, we will review your current plan and revise it to assure that it contains all the steps.  This effectively will help reduce your risk of fraud and offer the most protection for your organization.  

Our team consists of professionals with extensive backgrounds in healthcare law and anesthesia practice. We have been in the field of Anesthesia Compliance since 2002 and have assisted numerous organizations with their compliance programs. 

Pain Practices

Pain practices in anesthesia departments require special attention due to their style of practice and procedures for treatment.  Most practices bill using Evaluation and Management Coding in addition to billing for the procedures they perform.  We are very familiar with this style of practice and have created Compliance Plans for anesthesia pain practitioners in an office-based practice.  Secondly, the Compliance Plan we create will contain all appropriate federal and state rules and regulations in its policies and procedures.  

HIPAA Compliance Plans for Anesthesia

Is your organization prepared for Health Insurance Portability and Accountability Act (HIPAA)compliance?    Do you have a HIPAA compliance plan for anesthesia with policies and procedures?  If you do, have you recently reviewed your compliance plan, policies and procedures?  When we are engaged to consult on HIPAA we will review and revise your plan to assure compliance with HIPAA Rules and best practices. Moreover, if you don’t have a compliance plan, we will draft a plan with policies and procedures that offers complete coverage of the privacy, security and HITECH requirements that meet federal regulations and state law.

Business Associate Agreements

HIPAA requires that you have Business Associate Agreements with business partners that you contract with to provide non-treatment services if they access, use or disclose protected health information (PHI) on your behalf. Prime examples would include accounting, billing, legal, risk management and IT services.  Accordingly, we will help you identify business associates and provide business associate agreements for your organization.

Privacy Complaint Response and Breach Reporting

We are available to assist with responses to HIPAA complaints and investigate any privacy or security matter on your behalf whether from a patient, another individual or the Office for Civil Rights.   Anesthesia works with clients on the breach analysis to determine if they are dealing with a breach of unsecured PHI. For incidents that are reportable breaches there are steps and deadlines that one must follow for compliant reporting to the individual and to the Office for Civil Rights. Furthermore, we will assist you throughout the process from start to finish on all aspects including mitigation of damages, creating a corrective action plan, drafting notice letters and reporting to the OCR.  Most importantly, we are experienced in responding to Office for Civil Rights investigative letters and working with them to resolve complaints.

Compliance & HIPAA Consulting

Foremost we are available to consult and advise on all individual issues related to Anesthesia Compliance and HIPAA.  We have been in the business since 2002 and have extensive experience in anesthesia compliance and HIPAA compliance.  We charge on a project-based or hourly basis.