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Welcome!
This document contains the
Compliance Program Guidance for Hospitals. This document is not the
"official" version of the notice--the official document of
record was published in the Federal Register on February 23, 1998.
(If you would like to view the official version, click
here. Please note that you need Acrobat Reader to view this
document. Click
here for a free download.)
The OIG recommends that
organizations develop a compliance "library" from publicly
available materials. Specifically, the OIG noted in a subsequent
model compliance plan that—
Creating a
resource manual from publicly available information may be a
cost-effective approach for developing policies and procedures.
For example, the practice can develop a "binder" that
contains the practice's written policies and procedures, relevant
HCFA directives and carrier bulletins, and summaries of
informative OIG documents (e.g., Special Fraud Alerts, Advisory
Opinions, inspection and audit reports).
Davis Wright Tremaine LLP ("DWT")
has developed this resource, in an easy-to-use format, to
assist Compliance Officers and other persons in implementing part of
the OIG's recommendation.
In support of its positions, the
OIG cites various statutes, regulations, reports or other materials.
Most of the citations are in footnotes. When you come to a footnote
in the text of the plan, you may put your cursor on the footnote
link and click to go to that footnote. The footnotes contain
additional links. Putting your cursor on the links in the footnotes
and clicking will take you to the authority that the OIG cites in
support of its position. Using your cursor, you should be able to
maneuver easily from text to footnotes, linked documents and
websites.
As an example, if the OIG cites a
statute, regulation or report in support of its position, a link to
that statute, regulation or report is provided. As noted above, in
order to view many of the linked documents, you will need Adobe
Acrobat Reader, which may be obtained free of charge through the
links at the top or bottom of the screen.
The links to the cited documents
are made available for education and information purposes only. The
summaries and notes should not be considered legal advice. As the
OIG noted in footnote 7 of the Model Compliance Plan for Nursing
Facilities: "Counsel . . . should be consulted as appropriate
regarding interpretation and legal analysis of laws related to the
Federal health care programs and laws related to fraud, abuse and
other legal requirements." If you have questions or issues that
are specific to the operations of your practice, you should consult
your attorney.
The
DWT Health Law Department web site contains
client advisories and other materials that may be of interest to
persons developing, implementing or administering compliance plans. The
names and resumes of DWT attorneys who work with compliance plans
and issues are also provided. We have also attached an Appendix
of additional resources.
We hope you find these materials
useful.
Edwin D. Rauzi, Partner
edrauzi@dwt.com
The
author wishes to acknowledge the assistance of Danielle Chauncey and
the support of Joan White and the Health Care Association of Hawaii
in preparing these materials |
