“Everyone else is doing it” is a phrase we often hear in response to findings of compliance risks and violations.  Naturally, no one wants to be told they are doing something wrong.  As compliance professionals, we routinely rely on industry standards to help guide our practices.  We are well versed in fraud alerts, advisory opinions, and settlement agreements all of which are great resources for highlighting compliance risk areas.  However, are we considering what everyone else is doing as part of our internal risk assessment process?

The OIG publishes provider self-disclosures of fraud.  We have the opportunity to learn from what the compliance operations of our peers have uncovered.  Some of the common themes include:

• Billing for services not rendered
• Billing for services performed by unlicensed professionals
• Billing for services rendered by excluded individuals
• Billing for services that were not medically necessary
• Billing for services that were not properly supervised
• Billing for services that did not meet the coverage criteria

Currently, the OIG has published almost 700 fraud self-disclosures.  In the spirit of “everyone else is doing it” how likely is it that these types of compliance violations are occurring within your own organization?  Are these risk areas already included in your compliance work plan?  We recommend incorporating a regular review of the fraud self-disclosures into your compliance risk identification process.  

The OIG Fraud Self-Disclosure page is located here https://oig.hhs.gov/fraud/enforcement/?type=fraud-self-disclosures

HBE’s team of experts is available to assist you with conducting risk assessments, routine auditing and monitoring, policy and procedure development as well as customized education and training for your clinical and administrative staff.

DISCLAIMER:  This newsletter contains only summary information and highlights; it should be read in conjunction with the full article or document provided as a link.  Any advice or recommendations are general and specific questions should be directed to professional counsel.