Compliance

With the passage of the ACA, the voluntary nature of compliance programs is about to change. Smaller healthcare organizations and other ancillary providers who have previously not established compliance programs will now be required to adopt formal programs.  The ACA mandates providers and suppliers participating in federal health care programs to implement compliance programs with “core elements” as a condition of enrollment.

The HHS Secretary is responsible for setting a timeline to implement the new “core elements” for each health care sector and then setting a timeline for providers to adopt compliance programs.  Details regarding the extent of the program have not yet been described or published.  Skilled nursing facilities are the first providers required to implement an effective compliance program by March 23, 2013.

Our Insight.  Your Advantage.  By doing the work now, healthcare organizations can get ahead and avoid surprises when HHS eventually publishes the mandatory compliance program rules for other healthcare sectors. Many in the healthcare industry anticipate the OIG’s voluntary compliance program guidance will serve as an example to HHS as it determines which compliance program elements shall be required.  As you prepare your compliance programs, 

In the wake of the U.S. Supreme Court’s June 28, 2012, decision upholding the constitutionality of the 2010 Patient Protection and Affordable Care Act, employers who had been awaiting the decision should now focus on compliance. We expect additional guidance will be released to implement several pending provisions, including those related to the 2014 employer…

On July 10, 2012, two members of the Husch Blackwell Healthcare Group, Kate Mihalevich and Cori Turner, presented a webinar on ACO strategic physician alignment billing compliance.  The webinar:

  • highlighted compliance risks associated with ACOs and other physician alignment models; and
  • provided practical suggestions for evaluating and addressing risk in these areas.

To watch…

Is Your Organization Due for Re-certification by the Texas Medical Board?

If your organization is certified as a non-profit health corporation (formerly known as 5.01(a)s) under the Texas Occupations Code 161.001, your organization is required to submit a biennial report to the Texas Medical Board (TMB). For certified non-profit health organizations that were originally certified…