In the world of compliance, we do our best to stay out of the government’s crosshairs. Despite our vigilance, there is always the chance something will go wrong and it may appear to the government you are billing incorrectly, raising the risk of false claims allegations. To defend against this we recommend you adopt a compliance plan, perform audits and educate your staff. By performing these activities, you can “mitigate” or lessen the probability that there will be an action against the group and lessen the severity of the penalties in the event one occurs. Despite a recommendation from the Office of Inspector General to adopt the mitigation measures, anesthesia providers often forget the benefits they afford.
CMS makes this clear in their Compliance Policy and Guidance, which you can access below, in the active link. Please review this to fully understand how you can be prepared for potential issues.