Deeper Than the Headlines: Corporate Integrity Agreement-Digestive & Liver Disease Consultants

Though many CIAs read very similarly, it’s good practice to read new ones to reaffirm some of the core principles of an effective compliance program. It’s a great way to see the elements of a compliance program applied in a black and white, real-life way.

The OIG just posted its most recent Corporate Integrity Agreement (CIA), with Digestive & Liver Disease Consultants, P.A. (DLDC) and Dr. Gurunath Thota Reddy. Let’s check it out.

The Compliance Officer:

It’s import to pay special attention to the clear and strong language pertaining to the requirements for a compliance officer:

“The Compliance Officer shall be an employee and a member of senior management of DLDC, shall report directly to the Chief Executive Officer of DLDC, and shall not be or be subordinate to the General Counsel or Chief Financial Officer or have any responsibilities that involve acting in any capacity as legal counsel or supervising legal counsel functions for DLDC...Any noncompliance job responsibilities of the Compliance Officer shall be limited and must not interfere with the Compliance Officer’s ability to perform the duties outlined in this IA.”

Policies and Procedures:

The backbone of a compliance program is its policies and procedures. Policies need to be written, available to employees, reviewed and updated regularly. And employees need to be held accountable to them.

“DLDC shall develop and implement written policies and procedures regarding appropriate billing and medical record documentation for compliance with Federal health care program requirements...DLDC shall enforce its Policies and Procedures and shall make such compliance an element of evaluating the performance of all employees…At least annually (and more frequently, if appropriate), DLDC shall assess and update, as necessary, the Policies and Procedures. Any revised or new Policies and Procedures shall be made available to all Covered Persons.”

Communication (Hotline):

Effective lines of communication are an essential piece of a compliance program.  One tool towards that end is a hotline. The OIG’s requirement in the CIA was written this way:

“DLDC shall post in a prominent place accessible to all patients and Covered Persons a notice that provides the name and phone number of the Compliance Officer and the HHS OIG Fraud Hotline telephone number (1- 800-HHS-TIPS) as a confidential means by which suspected fraud or abuse in the Federal healthcare programs may be reported.”

Training and Education:

Without training, employees won’t be able to stay abreast of current rules and regulations. The CIA requires:

“All Covered Persons shall receive at least three hours of training…At a minimum, the required training sessions must include the following topics:

1. the Federal health care program billing, coding and claim submission statutes, regulations, and program requirements and directives relating to the services furnished by DLDC;
2. the Federal health care program medical record documentation requirements relating to services furnished by DLDC; and
3. the personal obligation of each individual involved in the medical record documentation and claims submission processes to ensure that medical records and claims are accurate.”

A lot of work goes into providing training. Compliance programs should make sure that they document all their training efforts.

“DLDC shall maintain written documentation (e.g., written or electronic certificates of completion from the training provider) that all Covered Persons required to receive training have in fact completed such training. The documentation shall specify the type of training received, the individual who completed the training, and the date received.”

These are just a few of the OIG’s most recently published CIA.  Read the full CIA

Make sure your compliance program could stand up to these kinds of requirements.  If it can’t, you may need to significantly up your game.